Magazine article Occupational Hazards

Mandating Safety Programs

Magazine article Occupational Hazards

Mandating Safety Programs

Article excerpt

OSHA is far from powerless to insist that employers, one at a time or in groups, implement comprehensive programs

If OSHA had its way, every employer in the country would have a comprehensive, fully implemented safety and health program. It would include a written program, management commitment, employee involvement, worksite analysis, hazard prevention and control, education and training, and program evaluation.

OSHA does not have the kind of control and authority to broadly mandate such elements, however. Attaining it through a performance-oriented standard for general industry will take years, and probably drive several OSHA administrators out of their regulatory minds. Industry leaders, trade associations and many in Congress are concerned that any such regulation will be too onerous and prescriptive. On the other hand, it could be so weak and vague that attempts to comply would be a waste of time.

OSHA lists the development of a safety program management standard as a regulatory priority. In the meantime, however, OSHA is far from powerless to insist that employers, one at a time or in groups, implement comprehensive programs. In the last couple of years, the agency has become more creative and diligent in this area.

The latest development is the Cooperative Compliance Program (CCP), which was started last month in federal OSHA states. The program targets about 12,000 employers whose lost workday injury and illness rates are at least twice the national average of 3.5 per 100 full-time workers. Covered employers who agree to "partner" with OSHA must implement or improve their safety and health programs. OSHA will inspect only a percentage of the partnering workplaces, but promises to do "wall-to-wall" inspections of workplaces that refuse to cooperate. (For more on CCP, see the article on page 35 in this issue.)

In construction, OSHA's focused inspections strategy drives the safety program movement. On sites with comprehensive programs, agency inspectors look at only four types of hazards: falls, struck by, caught in/between, and electrocution.

OSHA also uses high-profile enforcement cases to establish the terms of safety program implementation in ways that no standard ever would allow. Here are two recent examples:

* Armour-Swift Eckrich, Kansas City, Kan. - Late last year, the company agreed to pay $115,000 and upgrade its ammonia safety program beyond what is required by the process safety management standard. …

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