Compliance officers are expected to start using the Program Evaluation Profile, Form OSHA-195, for routine inspections in general industry before the end of the year.
The work sheets will be used to determine if employers qualify for focused inspections and "good faith" penalty reductions. They will also be turned over to companies to guide safety and health improvements.
Programs will be scored in six categories:
1. Management leadership and employee participation;
2. Workplace analysis;
3. Accident and record analysis;
4. Hazard prevention and control;
5. Emergency response; and
6. Safety and health training.
Each category, except for training, is broken down into specific "factors" as OSHA describes them, which also will be scored:
Management Leadership and Employee Participation
- Management leadership
- Employee participation
- Implementation tools
- Contractor safety
- Survey and hazard analysis
Accident and Record Analysis
- Investigation of accidents and near-miss incidents
- Data analysis
Hazard Prevention and Control
- Hazard control
- Medical program
- Emergency preparedness
- First aid
Safety and Health Training
Each of these factors will be scored on a scale of 1 to 5. OSHA has written descriptions of what would be going on at a worksite in order for a company to get a rating of 1-2-3-4-5
for each factor. For example, in the area of management leadership:
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 improved over time.
In total, OSHA has written 75 descriptions covering every rating possible for the 15 factors. Compliance officers will match the descriptor that best fits the worksite being inspected for each factor. The idea, according to Ray Donnelly of the agency's general industry compliance office, is to use the common descriptors as a means of bringing consistency to how inspectors conduct their assessments OSHA is using the philosophy of "a chain is only as strong as its weakest link" in rating worksites. For example, if a compliance officer assesses a worksite's workplace analysis element and gives the employer a "3" for survey hazard analysis, a "4" for inspection, and a "2" for reporting, the overall rating for workplace analysis is "2" because the lowest individual score was a "2". In the same way, the overall score for a worksite will be the lowest of the individual scores for the six categories. A site will be scored no higher than the least effective part of its program.
It should be noted that at press time OSHA's policies and procedures were still in draft form, subject to change. Agency officials are open to the need to be flexible. "Frankly, this is an untested form," says Donnelly. "I'd be the first to say this is an instrument that has not been validated. We may need a different tool for different size companies, or different industries." He also says a worksite's rating might not correlate with its injury and illness statistics, but he doubts this will be the case.
Explains Robert Kulick, area director of OSHA's Parsippany, NJ, office: "One of the things we've clearly identified through research is that in facilities where you have low injury, fatality, and lost-workday rates, you find effective safety and health programs." This is why the agency is going to use programs as compliance incentives and teaching tools in a more concentrated effort than safety and health pros have ever seen before.
Here's how OSHA officials responded to some specific questions about their safety and health rating system: Is this evaluation process going to bury employers in paperwork? Documentation is "part and parcel" of a good program, says Kulick, so employers shouldn't have to do much more than they would otherwise. Small employers are not expected to put everything down in writing.
How will OSHA avoid evaluating "paper programs"? Every OSHA compliance officer will be trained in conducting these evaluation profiles by October 1, 1995, and avoiding the trap of good-looking documentation is being emphasized. "We've all seen great programs in the front office, only to find a night-and-day difference in the workplace," says Kulick.
Donnelly says ratings will be based on reviewing documents, interviews with employers and employees, and personal observations in the workplace. What's being done to ensure consistency in evaluations across the country? Every compliance officer is receiving the same training, plus there have been case study exercises where inspectors have been consistent in their ratings, according to Donnelly.
He says once the program is rolled out, there will be biweekly conference calls with each regional office to compare notes. Obtaining consistency is largely a "conversational process," says Donnelly.
What are initial expectations? OSHA officials don't expect to find many outstanding programs. "I think we'll find a lot of partial programs that are strong in one area and not in another," says Donnelly.