Magazine article Occupational Hazards

For the Record: Are Your Documents in Order! Keeping Adequate Written Programs and Records in These Four Basic Areas Will Help You Protect Your Company against Potentially Significant OSHA Citations

Magazine article Occupational Hazards

For the Record: Are Your Documents in Order! Keeping Adequate Written Programs and Records in These Four Basic Areas Will Help You Protect Your Company against Potentially Significant OSHA Citations

Article excerpt

You are a safety-conscious employer. You have highly motivated employees who share your goal of sending each of them home to their families at the end of their workday free from any injuries or illnesses. You conduct regular safety meetings to keep everybody focused on safety as well as safety walkthroughs to ensure that hazards are not present in the workplace. You teach your employees to think before they act, to never take a shortcut that compromises their safety and to never walk past an unsafe condition without reporting it to a supervisor for correction. Your injury and illness rates reflect all of this good work. They are so low as to rank you at the top of your industry peers. You are feeling really good about your safety commitment and performance, and deservedly so.

So, you can rest easy with the knowledge that you have nothing to fear if OSHA were to show up at your workplace to conduct an inspection, right? Wrong. Unfortunately, you could still find yourself at the wrong end of a significant OSHA enforcement.

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How can this be? Well, your actual safety performance is commendable, but in your zeal to stay on top of day-to-day safety issues, you haven't put in place all of the written programs required under important OSHA standards. Nor have you paid much attention to creating and maintaining the many types of records required by OSHA that, in the minds of OSHA and its inspectors, establish to their satisfaction that you are a safety-conscious employer.

Even so, in view of your actual safety performance, you may still view this situation as a paperwork issue at most. Wrong again. You can be assured that OSHA won't share such a benign view of the deficiencies in your OSHA-required records.

Therefore, in order to fully protect your company against a potentially large number of citations and significant penalties, you need to make sure that you have in place the written programs and records that OSHA places so much importance on. The following is not intended as a listing of all OSHA-required programs and records. However, by pausing to make sure that you have addressed OSHA requirements in these four basic areas, you will have taken a big step down the path of being commended for your OSHA compliance as much as for your safety performance.

WRITTEN PROGRAMS

Many of OSHA's most important standards require that written programs be put in place. One of the most basic and familiar, of course, is the hazard communication program required by 29 CFR 1910.1200. Other important standards requiring written programs and procedures that may be applicable to your workplace include process safety management (1910.119), respiratory protection (1910.134), permit-required confined spaces (1910.146), lockout/tagout (1910.147) and blood-borne pathogens (1910.1030).

It is not enough, however, to simply issue such programs and then assume that compliance problems in these areas are behind you. A too common fault with such written programs is that, although they are initially implemented with much effort and fanfare, over time, as they become more routine, they also can become stale and lifeless. It is not so much a case of familiarity breeding contempt, but of familiarity breeding nonchalance. This is a recipe for creeping noncompliance. Because these programs address key safety areas in which a moment's inattention can lead to serious consequences, it is extremely important that the implementation of these types of programs be reviewed regularly to verify that they are effectively implemented, and that adjustments be made or additional training provided as is needed to keep them not only current, but also vibrant.

HAZARD ASSESSMENTS

The requirements of Section 1910.132(d) for workplace hazard assessments received a lot of very specific attention by employers in 1994 when the requirements first went into effect. Many employers took the opportunity to take a fresh look at their workplaces, conduct methodical hazard assessment surveys and make sure that appropriate personal protective equipment (PPE) needed to protect against hazards had been identified and was being properly used by employees. …

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