You have all your safety and health programs written and displayed in their own nicely titled three ring binders. All the regulatory procedures have been addressed such as;
- Hazard Communication,
- Personal Protective Equipment,
- Emergency Response,
- Fork Lift Training,
- Energy Isolation.
But for some reason it has had no or very little effect on your accident and incident rate. That rate remains too high in your opinion.
What is wrong?
This is an unrelenting complaint heard and voiced by so many employers. So what more can be done? What should you as an employer do?
Where to start?
First, understand your position as an “employer”. You under the Occupational Safety and Health Act (OSHA) are required to provide and ensure a workplace free from serious recognized hazards. This requirement or responsibility is accomplished through understanding the applicable OSHA rules and regulation which in part includes the development of a number of workplace safety and health policy and procedures. These required procedures if properly written will address those identified risk factors, applicable OSHA rules and regulations and if properly implemented reduce or remove those risk thus resulting in no loss time injuries.
Policies Procedures In Place, Now What?
Take a good look at those policy and procedures. Are they to “generic”? Were they developed or purchased pre-written and your company's name merely inserted where the template read “insert company name here”? This is a very common oversight made by so many employers. Many of these purchased programs are written and very well designed so as to meet the written portion of the OSHA requirement, but they are missing one of the most important elements of a facilities written policy and procedure. That element; the pre-written or “canned”, “one size fits all” programs neglect is the “site specific” application of those written procedures. Without considering your facilities layout, operational procedures, work force and other specific workplace elements it’s possible that your current safety and health policy and procedures simply cannot be adhered to, they just don’t apply to what you do. Take a good look at those policies. Read them carefully. What do they say you or your employees will actually do? Can you do the description of the procedures within them? Remember this; written policies are performance based procedures. As noted above, one size does not fit all. You need to tweak them out so they fit and address your facility while meeting the intent of the OSHA rule which the policy addresses. Don’t worry too much about the wording as referenced in the OSHA standard, think about the intent. What area or specific process is being protected or addressed within the described policy or procedure?
What Type of Accidents Are You Experiencing?
The next step and a very important step would be to take a look at your accidents which you are experiencing within your workplace. These should be easy to review since they are required to be recorded on the OSHA 300, Log of Work-Related Injuries of Illnesses. Other very good documents to review are your workers compensation or insurance provider accident illness reporting forms. Break down the recordable injuries. Are they associated with machinery, material handling, operational task, ergonomic concerns? See exactly where most of your injuries are occurring as in specific operations, specific equipment, and departments. The following step in this procedure is to identify the type of injuries, e.g. cuts, lacerations, object in the eyes, struck by, caught in between, slips trips or falls. Once this break down is completed you should have a very good map to follow reference to where to direct your attention.
Action Needed In Addressing The Areas of Concern.
Once you have a list or map of injuries identifying where and how they occurred along with the type of injury, you then can easily identify what needs to be addressed or acted upon. For example; if you find that the majority of your injuries resulted in cuts, laceration due to improper handling of a box cutter in the receiving area, that is where you want to focus. Some examples of action taken to possibly reduce or eliminate those injuries would be:
- Use of Safety – Retractable Blade Cutters.
- Receiving material in different types of containers where the need to cut open a box is eliminated.
- Use of proper personal protective equipment, hand, wrist protection.
These are just a few examples but you can see how your efforts can and should be focused in a more “site specific” nature.
If your mapping identified the majority of injuries were associated with slips and trips possibly a better housekeeping procedure needs to be implemented, or an improved material placement system be put into place.
Summary:
Simply having all your required safety and health policy and procedures in place does not and will not automatically result in an accident free workplace. You need to ensure that those procedures are addressing what exactly you do and what action, equipment or facility design is resulting in your recordable injury and illnesses. You may find that you have no policy or procedure in place addressing those accident prone activities.
Have a safe day.
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