Where safety and health programs begin ...

April 21, 2000
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Last month we gave you an overview of OSHA's Program Evaluation Profile, which is now being tested by inspectors in six field offices during routine compliance checks. This month you have the opportunity to see how your program would fare in the areas of management leadership and employee participation. We'll cover the rest of the PEP audit in coming months.

The charts below are used by OSHA compliance officers to assess programs in four key areas. What score would you give your program, based on the activity levels described for each rating? Remember, 1 = absent or ineffective, 2 = developmental, 3 = basic, 4 = superior, and 5 = outstanding. Higher ratings assume that all activity described for lower scores has been accomplished in addition to the activity listed for the level of performance that most closely matches your program.

Ray Colvin of Safety Training Dynamics in The Woodlands, Tex., provided us with these thoughts on management leadership and employee participation:

The key to success

The single-most important element of achieving a successful safety and health program is management leadership and support for the program. Managers actively support all programs they want to succeed. Programs that don't have their support cannot succeed.

Here's how you can tell if support is lacking: Safety is not a management priority; there's no formal safety budget; management does not actively oversee or measure the program's effectiveness; mid-managers are not encouraged to get involved; safety and health issues don't get the kind of attention that goes to production, sales, advertising, and other issues of the day.

If managers do not believe safety is a priority, they will not allow their supervisors and employees adequate time for meetings and training away from production.

Managers are also responsible for getting contractors to become involved in the safety and health program. They set policies and procedures, and make sure these requirements are being followed.

This part of the PEP audit is an opportunity for you to demonstrate to managers and employees the importance OSHA puts on these fundamental elements of workplace safety and health.

Management leadership

Visible management leadership provides the motivating force for an effective safety and health program. [1989 Voluntary Safety and Health Program Management Guidelines, (b)(1) and (c)(1)]

1. Management demonstrates no policy, goals, objectives, or interest in safety and health issues at this worksite.

2. Management sets and communicates safety and health policy and goals, but remains detached from all other safety and health efforts.

3. Management follows all safety and health rules, and gives visible support to the safety and health efforts of others.

4. Management participates in significant aspects of the site's safety and health program, such as site inspections, incident reviews, and program reviews. Incentive programs that discourage reporting of accidents, symptoms, injuries, or hazards are absent. Other incentive programs may be present.

5. Site safety and health issues are regularly included on agendas of management operations meetings. Management clearly demonstrates - by involvement, support, and example - the primary importance of safety and health for everyone on the worksite. Performance is consistent and sustained or has improved over time.

Employee Participation

Employee participation provides the means through which workers identify hazards, recommend and monitor abatement, and otherwise participate in their own protection. [Guidelines, (b)(1) and (c)(1)]

1. Worker participation in workplace safety and health concerns is not encouraged. Incentive programs are present which have the effect of discouraging reporting of incidents, injuries, potential hazards or symptoms. Employees/employee representatives are not involved in the safety and health program.

2. Workers and their representatives can participate freely in safety and health activities at the worksite without fear of reprisal. Procedures are in place for communication between employer and workers on safety and health matters. Worker rights under the Occupational Safety and Health Act to refuse or stop work that they reasonably believe involves imminent danger are understood by workers and honored by management. Workers are paid while performing safety activities.

3. Workers and their representatives are involved in the safety and health program, involved in inspection of work area, and are permitted to observe monitoring and receive results. Workers' and representatives' right of access to information is understood by workers and recognized by management. A documented procedure is in place for raising complaints of hazards or discrimination and receiving timely employer responses.

4. Workers and their representatives participate in workplace analysis, inspections and investigations, and development of control strategies throughout facility, and have necessary training and education to participate in such activities. Workers and their representatives have access to all pertinent health and safety information, including safety reports and audits. Workers are informed of their right to refuse job assignments that pose serious hazards to themselves pending management response.

5. Workers and their representatives participate fully in development of the safety and health program and conduct of training and education. Workers participate in audits, program reviews conducted by management or third parties, and collection of samples for monitoring purposes, and have necessary training and education to participate in such activities. Employer encourages and authorizes employees to stop activities that present potentially serious safety and health hazards.

Implementation

Implementation means tools, provided by management, that include:
  • budget
  • information
  • personnel
  • assigned responsibility
  • adequate expertise and authority
  • means to hold responsible persons accountable (line accountability)
  • program review procedures. [Guidelines, (b)(1) and (c)(1)]

1. Tools to implement a safety and health program are inadequate or missing.

  • 2. Some tools to implement a safety and health program are adequate and effectively used; others are ineffective or inadequate. Management assigns responsibility for implementing a site safety and health program to identified person(s). Management's designated representative has authority to direct abatement of hazards that can be corrected without major capital expenditure.
  • 3. Tools to implement a safety and health program are adequate, but are not all effectively used. Management representative has some expertise in hazard recognition and applicable OSHA requirements. Management keeps or has access to applicable OSHA standards at the facility, and seeks appropriate guidance information for interpretation of OSHA standards. Management representative has authority to order/purchase safety and health equipment.
  • 4. All tools to implement a safety and health program are more than adequate and effectively used. Written safety procedures, policies, and interpretations are updated based on reviews of the safety and health program. Safety and health expenditures, including training costs and personnel, are identified in the facility budget. Hazard abatement is an element in management performance evaluation.
  • 5. All tools necessary to implement a good safety and health program are more than adequate and effectively used. Management safety and health representative has expertise appropriate to facility size and process, and has access to professional advice when needed. Safety and health budgets and funding procedures are reviewed periodically for adequacy.

    Contractor safety

    Contractor safety: An effective safety and health program protects all personnel on the worksite, including the employees of contractors and subcontractors. It is the responsibility of management to address contractor safety. [Guidelines, (b)(1) and (c)(1)]

    1. Management makes no provision to include contractors within the scope of the worksite's safety and health program.

    2. Management policy requires contractor to conform to OSHA regulations and other legal requirements.

    3. Management designates a representative to monitor contractor safety and health practices, and that individual has authority to stop contractor practices that expose host or contractor employees to hazards. Management informs contractor and employees of hazards present at the facility.

    4. Management investigates a contractor's safety and health record as one of the bidding criteria.

    5. The site's safety and health program ensures protection of everyone employed at the worksite, i.e., regular full-time employees, contractors, temporary and part-time employees.

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