One-Stop Safety Programs...Beware

If you have elected to purchase a 'safety program' from one of many online sources you need to know a few things. I have been working with clients who have done just this...purchased a safety manual from a company for a nominal annual fee to keep their subscription. I want to shed some light on the risks associated with this practice and provide some recommendations for your company moving forward into a compliant state.

First, many OSHA standards require your safety programs to be specific to the work you do. If you are buying a pre-fab safety manual that does nothing more than put your company name in the right spots, you are getting duped. Did you sign a form that told you that you would not hold this company accountable if their program was not adequate? Did you absolve this company of any and all liability, including time spent updating said program to meet the requirements of the MANY pre-qualification companies bigger companies are using today? Probably not. As such, you are going to have to do a lot of leg work yourself to get compliant or you will have to hire someone to do it for you. Now I don't want to get into pre-qualification companies and how ridiculous their expectations are in this post because I could rant for hours. Let me use something like the new OSHA silica standard as an example. I can guarantee your pre-fab safety manual does not address the specific tools and work that you do and how you will prevent worker exposure...yet, this is the expectation from OSHA. You have paid all this money for a non-compliant safety manual. How about Global Harmonization (HAZCOM to most of us). This standard requires you inventory all chemicals your workers are exposed to and take whatever action is required to protect them. Let me tell you...if you are relying on a Safety Data Sheet to tell you what protective equipment your workers need to wear, you will find yourself wanting. You have to do your own research and find the right protective equipment for your people. Do you see a trend setting in? I could go on and on. Permit Required Confined Space Entry. Lockout/Tagout. Scaffold Use. Trenching and Excavation. This list goes on and on. Where the rubber meets the road is, your programs have to be specific to your company's expectations.

You have to spell out how you expect your workers to behave in the field. Likely, and let's be open and honest about this, if you purchased one of these safety manuals, you have never trained workers on your expectations. Rather, you may have had them complete an online training course that they will remember 20% of if you are lucky. When it comes to training you need to know something. OSHA states that training needs to be effective. When they use this term, it means the worker needs to remember the training and properly employ work tactics that prevent them from exposing themselves to hazards. Now, in the spirit of transparency, OSHA is not likely to jump on this unless there has been a serious injury or fatality but why risk it? You need to do training that means something to your workers...that they will remember...and follow up on that training regularly. You want your workers to assimilate to the culture you are trying to develop. If you don't have one...ouch. If you have an idea of one but don't know how to implement it, you may need to hire someone like me to help you. This isn't a pitch for my business. There are a lot of people out there that can help you but buyer beware...please do your homework. There are also a lot of under-qualified safety and health professionals out there looking to take your money and not provide you the service you expect.

Your safety manual (programs) are designed to be an extension of your company's safety culture. I know that this is difficult to understand for most people but let me give you an example. I have a client, who I will not name, who has a great pre-fabricated safety manual. Even so, I have spent many hours working with them to get them into compliance with pre-qualification companies. The problem is...it's all paperwork. I update their program to satisfy these companies and there is ZERO follow up to ensure there was an appropriate change (i.e. training) for the workers. In reality, the workers see no benefit to the appropriate correction to their company's programs. These pre-qualification companies give them a pass. If this is you, you need to think about your workers. If you are a company using these companies to pre-qualify sub-contractors, you need as ask yourself if you should be doing this yourself. I know...it takes a lot of time and effort to do this yourself. How do I know? I used to do this for every company that worked for me. Yes, it took a lot of my time up front but it saved me a lot of time on the back end.

One final thought on this and this is where we need to be honest. Do you really care about your workers? These programs are not intended to simply be a requirement by OSHA. They are intended to drive safe behaviors with our workers? They are intended to be living, breathing documents that we review and train our people on a regular basis. They need to be that. They need to be functional, in a language people understand (another discussion), and they need to be active. When I say active I mean you need to be talking about it and reviewing it on a regular basis in the field. I know it sounds daunting but when you have a solid, site specific program it becomes easy to set expectations. Your are now on your way to developing a safety culture, which is again a separate discussion point. If you elect to use a company or already have used a company to provide you a safety program...buyer beware...