FAILING TO PLAN IS PLANNING TO FAIL

There are many iterations of this poignant thought, and variants of the quote are attributed to as many different historical figures.

A business that has success in view should have a solid business plan. Financially successful households – and businesses – have a plan in the form of a budget. Students matriculating in higher education are required to choose a discipline, which will require a plan. Athletic teams have playbooks – or a plan. My weight loss success is hit or miss because I sort of have a plan and I sort of follow it…

Too often deficiencies in employers’ safety programs – or more explicitly, Safety and Health Management Plan (SHMP) OSHA, or Occupational Health and Safety Management System (OHSMS) ISO – are discovered by accident. Pun intended.

An accident occurs and a weakness or failing in policy or training is revealed through the investigation. Perhaps there was no policy or training to begin with.

An OSHA Compliance Officer shows up and citations follow, perhaps not for many direct safety violations or hazards to be cited, but an audit of programs, policies, training records, recordkeeping, etc. yields a handful of citations.

The ultimate goal – and insulator from the collateral discoveries and citations – is to have a solid SHMP that includes the pertinent training.

Do you have a SHMP or an OHSMS? It is not required to have the formal name, and that is absolutely fine. The question or point is, do you have a plan? What is the basis for your new employee safety orientation? You do provide basic safety training for all of your employees, right? Beyond that, you must ask yourself the following questions.

• What training is required annually for every employee?
• What task specific and equipment specific training requires workers to be certified?
• How is the required Personal Protective Equipment PPE determined?
• How are employees kept safe when required to perform maintenance on equipment that has energy sources?
• How are employees informed of chemical hazards and kept safe when working with various chemicals?
• What if an employee gets hurt while on a job in a city or rural location they are unfamiliar with?
• What happens if a small fire breaks out?

The answers to these and all other employee safety related questions are found in a solid SHMP or SHSMS or Company Safety Manual.

To be clear, having one of these plans is not regulatory, meaning an employer won’t get cited simply for not having one, but it is best practice in that it guides the employer through a systematic approach to uncovering, understanding, and mitigating hazards. Many General Contractors require subcontractors to have and share their Safety Manual. ISNetworld clients and other contractor compliance/management systems require company Safety Manuals before workers can enter their facilities.

This being an introduction to a series of articles, we will look at the basic components of an effective SHMP. OSHA 29 CFR 1926 Subpart C gives this basic structure. An effective occupational safety and health program will include the following four main elements: management commitment and employee involvement, worksite analysis, hazard prevention and control, and safety & health training.

Here’s what these will look like:

1. Management Commitment and Employee Involvement: Employers’ top leadership must promote a safe working environment while de-incentivizing unsafe behaviors and practices. Employees should be involved in shaping the safety expectations as well as know that their concerns will be addressed.
2. Worksite Analysis: Jobsite Safety Surveys are very important. Complete regular inspections on the job to identify and mitigate any hazard before it becomes an incident or accident. Management, Supervision, and workers should be involved in these inspections.
3. Hazard Prevention and Control: This is in the form of conducting a PPE Hazard Analysis and job hazard analysis for every task and describe the controls for each task. Match the control to the risk. - Corrective Action: This should not only occur after an incident. During inspections you see what’s wrong, or you see what can be done more effectively. Now it’s time to take action to fix the action or behavior.
4. Safety and Health Training: Beginning with new employee orientation, every worker/employee needs to be part of the SHMP. Develop a clear communication strategy for controls and processes to employees to build on the safety program.

This being an introduction to a series of articles, we will look at the basic components of an effective SHMP. OSHA 29 CFR 1926 Subpart C gives this basic structure. An effective occupational safety and health program will include the following four main elements: management commitment and employee involvement, worksite analysis, hazard prevention and control, and safety & health training.

In reality, developing or improving your SHMP – or whatever you may call it – is not as daunting as it sounds. For the most part, I would guess that you already have far more right than wrong. Now, it is about getting all of the tools out of the toolkit and putting them to work.

Since construction begins with the foundation, we will look at training requirements in the next article.

3836 Safety is available to assist from where you are right now, to developing an effective OSHA compliant Safety and Health Management Program or ISO Occupational Health and Safety Management System.

Jon Isom, Owner/Senior Consultant

3836 Safety, LLC – 901-600-6746 – [email protected] – www.3836safety.com

We manage your safety compliance so you can manage your business!