There are certainly pros and cons when dealing with data and paperwork. Some data we can’t live without and other information just seems to overwhelm the system. Certain records we have to have and some records take on a life of their own.
The best way to assure an OSHA inspector that you have a good safety program is by being able to provide any and all documentation that they request. No doubt about it, keeping up with data and paperwork is a challenge, but it can be done. Here’s an overview of eight types of information that you shouldn’t be without.
1) Records
If you don’t keep any other records, at least make sure you keep your OSHA 300 log up to date. The first thing an OSHA inspector asks for is the last three to five years of OSHA logs. Keep current and recent logs in a very convenient location and get in the habit of updating them the day a recordable injury occurs. Remember to keep the totals of both lost days and restricted days up to date on a regular basis.
2) Injury reports
Having an injury report for every injury not only helps you track your injuries and injury trends, but they are absolutely necessary when injuries become workers’ compensation cases. Information about past injuries and illnesses need to be kept forever. You never know when that data may be needed for legal matters, etc.
Without going into injury reports in detail, one critical item is to have the injured employee write out their own description of the injury and why they think the injury occurred. Having that information in someone’s own words will be important if a case comes back in play for any reason in the future.
Injury reports can be a good source of data that can help you track things such as part of the body injured, at-risk behavior that caused the injury, areas that injuries are occurring and many other details depending on your injury reports.
3) Procedures
Every safety-related program that you have in place should have a written procedure. Safety procedures should cover the information shown in Table 1 (below) regardless of what the specific topic may be.
Safety procedures need to be updated yearly, and the review date and who performed the review should be clearly placed on the document.
4) Training
There are two types of training records:
1. Proof that the employee attended the training must be maintained.A sign-in sheet or, even better, a signed test covering the training topic would be adequate proof. If someone came to you today and asked if a specific employee had been trained on hazard communication, would you be able to go to that information? It is another item that OSHA inspectors will ask about.
An easy system is to have a sign-in sheet and then make as many copies as there are students. Highlight each individual name and place it in their training folder. A spreadsheet to go along with this information is also handy to help you see who has — and has not — had the training.
2. An example of the training curriculum should be kept available.For example, if you use PowerPoint slides for the topic, just print out a copy and place it in a folder for that subject. A folder for Hazard Communication might have the following information.
- A copy of the Hazard Communication procedure;
- A copy of the OSHA Hazard Communication Standard;
- An outline of the training class agenda;
- A printout of the training slides;
- A copy of any tests or demonstrations that had to be completed before finishing the class;
- The original sign-in sheet.
5) Inspections
Always keep records of all safety inspections and safety-related audits. A safety inspection should state what area was inspected and some of the specific items that were inspected, such as safety showers and fire extinguishers. It should include information that answers all of the following questions:
- Who was doing the inspecting?
- What was identified as a concern?
- What action was needed?
- Who was assigned to the action?
- When was the action completed?
Performing the inspections is the easy part. Making sure that each concern is followed to closure is the challenge.
6) Industrial hygiene monitoring records
Data on any item that you have monitored should be kept and accessible. Typical monitoring information includes:
- Indoor air quality;
- Noise exposure testing;
- Air testing for welders and welding areas;
- Dust testing.
7) MSDS
Material safety data sheets and chemical lists are another form of documentation that is a vital part of a good safety program. Keeping the MSDS sheets of all chemicals at your work site is required, but, at the same time, it is a good idea to keep a detailed chemical inventory list. MSDS programs can be hard to manage, especially when you have a location that has a large number of chemicals.
8) PPE assessments
Simply having personal protective equipment available for your employees doesn’t mean you are complying with the PPE standard. OHSA regulation — General requirements 1910.132, Personal Protective Equipment states that:
The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE). If such hazards are present, or likely to be present, the employer shall:
Select, and have each affected employee use, the types of PPE that will protect the affected employee from the hazards identified in the hazard assessment;
This regulation does mean more paperwork. PPE assessments are a basic part of the regulation. Assessments need to be performed and they must be retained so that you can refer to them when needed.
Records retention
As the years go by, the boxes of paper will accumulate. Make sure that you have a records retention system in place to enable you to locate documents as easily as possible. There are companies that offer document storage services.
This article has covered the basic data needed for a good safety program. Of course, there are many other types of safety data, and many of them depend on the specific company and/or location. Typical records might include confined space entry and hot work permits, safety shower inspections and job hazard analyses. If a behavioral process is in place, a whole other area of data will need to be kept and monitored.
Keeping your data, records and documents up to date and accessible will make your safety program easier to manage and save you time in the long run.
Table 1. Written safety procedures should include:
Purpose = What the procedure is forScope = What the procedure will cover
Regulation = What regulation it addresses
Definitions = What specific terms mean
Details = Specific details of the topic
Training = What training is needed
