Most employers are in woeful shape when it comes to having written environmental health and safety programs. For example, the most frequently cited OSHA violation in general industry in recent years has been failing to have, or having an insufficient, written hazard communication program. And in a survey estimate of 123,200 manufacturing plants that used respirators, OSHA found that only 25.5 percent had a required written respiratory protection program. Only about 8 percent had a written program that would comply with OSHA's pre-1998 respiratory protection standard.

There are ways to break this EHS writer's block, especially since most safety and health programs contain a high percentage of common 'boilerplate' language. Services will sell you pre-written, ready-to-edit OSHA programs on a floppy disk (see the classified ads in back of this magazine). You can also obtain written programs from the Internet.

Copyright concerns

But be careful. Contrary to popular opinion, all written works and graphics on the Internet, except for limited exclusions such as works created by a government agency, are afforded copyright protection automatically when the work is created. A written work does not have to be registered or have a copyright notice or copyright symbol © affixed to it to secure copyright protection. You can learn more about copyright basics from the Internet site at It's fairly safe to say, though, that you can freely use a document on the Internet if a copyright notice and/or symbol does not accompany it. Your best bet is to always obtain written permission from the owner of an Internet work before you use it.

Still, we may be accused of plagiarism if we modify someone else's written work and call it our own. The academic community is in an uproar now over some Internet sites that are offering to sell thesis papers on almost any topic. These are actual thesis papers that earned an 'A' in some college course. Not surprisingly, these sites are getting thousands of hits.

Written EHS programs, however, are not literary works of authors who are concerned with plagiarism. We shouldn't fret much over this issue. I believe any EHS professional would be proud to share a word, phrase, or even entire document that will help prevent an injury or illness. We can avoid or reduce plagiarism concerns by giving credit for borrowed work. Simply stating that the program was adapted from another source, and then citing the source, may be all that is needed.

Quality control

A serious concern with obtaining and using information from the Internet is that the information may be incorrect, or may be damaging if applied without modifying it to fit the specific needs of another workplace. Let's say you obtain a written respiratory protection program that specifies an incorrect respirator for a chemical hazard that is also common to your workplace. If you are not aware of the error and also specify the wrong respirator . . . well, you can see where big problems may arise.

So far, we have just talked about written programs. The cut-and-paste concept can be extended to training programs. You can find some training programs on the Internet that you may be able to freely use. Start by searching the OSHA and NIOSH web sites.

Training programs also contain a lot of common information. Why develop your own training program when someone else's will work just as well? This question has led to the development of partnerships such as LearnShare. LearnShare is a group of non-competing organizations such as Aeroquip-Vickers, General Motors, GTE, Motorola, Northwest Airlines, and The Ohio State University that 'share' their in-house training programs.

For example, I developed a PowerPoint program on bloodborne pathogens that I feel is an excellent work. The bloodborne pathogens and other training programs that I have developed are available for use and modification by any other LearnShare member. Likewise, I can use and modify a safety and health program developed by any other LearnShare member. The sharing arrangement is intended to save each member time and training costs.

Developing an idea from scratch and bringing it to completion is often tough work. Writing is particularly difficult for many people. If you're having trouble developing material, consider the options presented by various training vendors, the Internet, and perhaps by partnering with other companies. But don't get the impression that you can snatch any work and call it your own. Examine copyright issues carefully – and also the quality of the information you're using.

There's another reason why many companies have inadequate written programs and training material, and it has nothing to do with writer's block, ignorance, or laziness. Lack of time seems to be a growing enemy for every EHS pro. In next month's article we'll tackle time problems in greater depth.