Key Elements of a Safety Management Program
What goes into a safety management program?
Every organization’s safety management program should reflect the work done and regulatory requirements. Even so, you will find that almost every safety program includes these elements in some form:
- Management Commitment to Safety
- Written Safety Programs and Procedures
- Employee Involvement
- Employee Training
- Hazard Recognition and Control
- Accident and Incident Reporting
- Incident Investigations
- Using Incident Analysis
Management Commitment to Safety
Management commitment to safety is how members of management (Owners, Plant Managers, Supervisors, etc.) take an active posture in the control of safety and health. Their commitment includes defining and putting into practice policies and systems for recognizing and minimizing hazards to ensure a safe and healthy workplace for all employees.
In addition, management ensures that safety becomes an integral part of all company activities and objectives.
Leadership should support, encourage, and recognize workers who work safely. They should also recognize those who participate in making the company safer by taking actions like reporting hazards or proactively suggesting safer ways of accomplishing tasks.
Most written safety plans include a declaration that “management is committed to employee safety” or “safety is job #1.” However, these declarations are only words. Effective management demonstrates commitment when they:
- Set an example by making time and funds available for safety improvements
- Modify rules and procedures when a better suggestion appears
- Make themselves visible to and take an interest in employees
- Follow the same rules set for all employees
Written Safety Programs and Procedures
Low-hazard general industry businesses that do not manufacture products and have office-bound employees may require as few as five written plans and programs.
Construction companies, manufacturers, utilities, and higher-hazard industries may have 25 required written programs in their Safety Manual. You can find some OSHA sample programs on the OSHA site.
To identify the programs needed, people from all company departments with knowledge of operations and procedures should conduct an evaluation and compliance gap analysis.
The evaluation is a comprehensive safety audit. You can use it to determine what areas require compliance with safety standards and which topics don’t apply to company operations. Many standard inspection templates exist.
The OSHA Small Business Handbook contains guidance on evaluating which safety programs apply to your company.
Standard Operating Procedures (SOPs)
Standard operating procedures (SOPs) provide detailed guidance on routine and repetitive operations. These tasks may include maintenance procedures, tool set-ups, and machine operating instructions. SOPs are also useful for specifying the “who” and the “how-to” for standing procedures such as building evacuation, emergency actions for medical emergencies, fire, etc.
An SOP works when the “how-to” is static, but the personnel assigned to take action may change over time. Because SOPs are shorter and more detailed than written programs, you will find it easier to change them when necessary.
Along with the “high level” guidance program documents (i.e., Hazard Communication Program, Lockout-Tagout Program, Emergency Action plan, etc.), the safety management system also requires other more focused procedures and standard forms.
Job Hazard Analysis (JHA) forms evaluate hazards and risks to personnel. JHA forms are also tools to analyze the personal protective equipment or respiratory equipment required for the plant’s job tasks or areas. The Hazard Recognition section below discusses the JHA and Risk Matrix process in detail.
You must store all of the written procedures, forms, and documentation in an accessible location (either physically or electronically, or both). Records must be kept of revision history, so only the document’s current version is available for use.
Implementing a safety management system should happen from the “ground-up” rather than from the “manager’s office down.” A ground up approach involves employee input, which is critical to an effective, functioning safety program.
Employees from all organization levels should work together when developing written programs, creating JHA’s and JSA’s, and choosing new processes and equipment for installation.
Running Safety Teams
Many companies have an Employee Safety Committee or Safety Team. OSHA considers such involvement to be critical to a company’s safety success.
According to OSHA: “In an effective safety and health program, all workers:
- Are encouraged to participate in the program and feel comfortable providing input and reporting safety or health concerns.
- Have access to information they need to participate effectively in the program.
- Have opportunities to participate in all phases of program design and implementation.
- Do not experience retaliation when they raise safety and health concerns; report injuries, illnesses, and hazards; participate in the program; or exercise safety and health rights.”
Employees must have the time and resources necessary to participate in safety-related activities. They also need the authority to bring issues to management for resolution without fear of reprisal.
As a result, participation in safety committees should be voluntary. Acknowledge those who participate and possibly even reward them for going above and beyond their job description to make the workplace safer and healthier for everyone.
Part of the importance of assessing which OSHA compliance topics apply to your business is that it allows you to determine the type and quantity of training required for safer work.
Most safety regulations involve some form of awareness and understanding. However, not all of them require in-depth skills-based training or specific documentation.
First, you must determine which topics require specialized training (i.e., Confined Space Entry, Lockout-Tagout, etc.) and which ones you can roll into new hire orientation or annual awareness training (i.e., electrical safety for non-electrical workers, ergonomics, safety signs and tags, etc.).
Note: You may need to provide additional training depending on the job responsibilities of individual workers, supervisors, and managers.
Practical training and education can happen outside a formal classroom setting. Peer-to-peer training, on-the-job training, daily toolbox talks, and worksite demonstrations are effective in conveying safety concepts, ensuring understanding of hazards and their controls, and promoting good work practices.
Hazard Recognition and Control
According to OSHA, the goal of hazard control is to “…furnish…a workplace that is free from recognized hazards that are causing or likely to cause death or serious harm.”
To accomplish this, the management needs to make hazard recognition and control a key part of the safety program.
Hazard recognition starts with frequent facility or site walks designed to identify likely unsafe conditions.
These walks identify hazards like wet or uneven walking surfaces, which could lead to trips and falls, unguarded equipment, spills, or leaks.
Other aspects of hazard recognition and control include:
- Collect and review information about workplace hazards
- Investigate injuries, illnesses, incidents, and near-miss accidents to determine the underlying hazards, their causes, and safety and health program gaps
- If possible, fix hazards as you find them. If you can’t, take steps to isolate the hazard from employees and put a plan in place to remove it as soon as practicable
- Analyze the hazards of complex or non-routine operations, identify interim control measures and communicate hazards to company personnel
Hazard Control Never Ends
Hazard recognition and analysis is not a task that is ever truly complete. It’s a continuous process. As soon as you recognize and deal with one hazard, you will inevitably observe another introduce by a new substance, process, or facility modification.
That’s why you need both formal and informal hazard analysis inspections.
Your hazard control program will benefit from involving different (even outside) personnel. Why? Because plant operators get used to seeing the facility over time. Familiarity means you can miss issues that are obvious to a fresh set of eyes!
Accident and Incident Reporting
Regulations issued under OSHA require all employers with ten or more employees at any time during the previous calendar year to maintain records of occupational injuries and illnesses using the OSHA 300 Summary.
The purposes of the OSHA recordkeeping requirements are four-fold:
- Assist compliance offers in the determination of the company’s injury experience.
- Ensure you gather uniform statistical information.
- Inform employees of their employer’s injury/illness experience by posting the information.
- Assist the employer in identifying trends of occupational injuries and illnesses and determining corrective actions.
OSHA defines a recordable injury or illness as:
- Any work-related fatality
- Any work-related injury or illness that results in loss of consciousness, days away from work, restricted work, or transfer to another job.
- Any work-related injury or illness requiring medical treatment beyond first aid.
- Any work-related diagnosed case of cancer, chronic irreversible diseases, fractured or cracked bones or teeth, and punctured eardrums.
There are also particular recording criteria for work-related cases involving:
- Needlesticks and sharps injuries
- Medical removal
- Hearing loss
Keeping the OSHA 300 Log
Each employer must keep injury and illness records for every establishment. An establishment is defined as a “single physical location where business is conducted or where services are performed.” This means each separate location such as a construction site, plant, office, shop, lab, or warehouse.
- Obtain the OSHA Log sheets from the Safety Department. (Normally, the safety department is responsible for the log).
- Record all occupational injuries and illnesses within seven calendar days of your knowledge of the occurrence (sooner if possible).
- Keep the Log in the file with your First Reports of Injury. The OSHA 300 Summary shall be completed and posted no later than February 1 of the year following the calendar year covered and shall remain in place until January 31 of the following year.
Accidents are unplanned events that result in disruption of the workflow, personal injury (or illness from exposures at work), or property damage. Since the word “accident” implies something that happens by chance, we should stop using it in occupational safety. Instead, we should substitute the word “incident,” which simply means an “event or occurrence.”
It is critical for companies to track and learn from incidents that result in injuries or serious loss. OSHA requires companies to do more than report injuries and fatalities. Companies must also understand the causes and fix unsafe equipment or process failures that may have led to the incident.
Incident investigation determines how and why the event happened. The value of incident analysis lies in thoroughly understanding all of the factors that led to the incident. This includes identifying the safeguards in place and why they did not prevent the incident.
Although there are dozens of approaches and techniques available for incident investigation, the basic methodology involves the following steps:
- Assign Responsibility for the investigation, define the scope, assemble the team.
- Fact-Finding: (i.e., visit the incident site, review statements, and photos, interview witnesses, assemble written procedures, maintenance logs, etc.)
- Develop a Narrative: (i.e., assemble a timeline of events leading up to the incident based on the results of fact-finding.)
- Causal Analysis: (i.e., using the information from steps two and three, determine the key points where alternate action could have avoided the incident. If possible, try to find the most direct or “root” cause of the occurrence.)
- Corrective Actions: Select corrective actions based on the causal factors from step 4. Avoid the “blame the worker” mindset. Practical corrective actions follow from the hierarchy of controls, with engineering solutions being the most effective. Administrative corrective actions like “re-training” and “install warning signs” are prevalent. However, they are not effective in the long-term because they depend solely on employee action. Installing guards and interlocks, substituting less toxic substances in the process, or separating workers from the hazard are the most effective ways of preventing a recurrence of a similar incident.
- Lessons Learned Communication: Although not part of the incident investigation per se, communicating the knowledge gained from the investigation and the corrective actions taken throughout the organization (and filing them for future use) is a great way to show employees you are serious about improving safety.
Using Incident Analysis
Incident analysis focuses on behavioral and system failures that result in injuries or process interruption. The effort you put into understanding “what went wrong” and fixing it prevents the recurrence of the exact same failure (assuming the corrective actions selected suffice).
However, focusing solely on preventing recurring failures precludes an understanding of 99.99% of the other actions that do not result in accidents. In other words, safety staff often spend time looking at the wrong things.
The process of incident analysis can be used proactively to look at high-hazard operations before an incident. The results can determine where the possible failure points might be and what the current workers are doing right.
Often, incident analysis reveals process steps and innovative techniques developed in the field or on the line that don’t appear in the standard operating procedures or worker training.
The ability to align management guidance and expectations with how the work really gets done and cooperatively develop acceptable procedures is the hallmark of a world-class safety management system.
To establish and maintain a safety-centered workplace, all levels of the organization must have access to safety information and guidance. Access is achieved through effective communications. Safety guidelines and rules, emerging safety hazards, warnings and goals, and progress status are examples of information shared throughout the company. Traditional communication media such as posters, bulletin boards, and stand-up meetings still have a role. However, companies who use a distributed, mobile workforce need to use digital tools to spread the word about safety.
Implementing an efficient and effective way to provide regular safety updates to field employees is critical. By embracing these digital means of communications, companies have the ability to reach all employees — whether they are in a field 100 miles away or at their desk in the corporate office.
Safety software collects, analyzes, and prepares data to display on an array of media. This information used in real-time creates a safer and more productive workplace and keeps every employee up to date.
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