Keeping the Enemy from the Gates: Preventing an OSHA Visit

The best way to prevent an OSHA is to never have an accident and never have a recordable injury. Actually the best way is to not have a company... but short of that here are my tips on how you can make your work environment a MUCH safer place.

• Realize that safety is an ATTITUDE THAT STARTS AT THE TOP! Key executives must have an awareness of safety and enforce safety as a priority. If they do not then why should anyone else down the line. If employees see an executive, the plant manager, the department manager, the shift supervisor or the HR representative walk past an unguarded machine, a discharged fire extinguisher, a wet spot on the floor or any other safety hazard and not do anything about it then a BIG "I DON'T CARE" has been broadcast. A good safety program will pay for itself in reduced workers' compensation claims. So $$$$ to the bottomline may help foster the attitude. But if that doesn't work you can make your executives realize that they may now be held personally liable for safety violations that cause injury or death and pay hefty fines and go to jail. In jail most executives would not be on the top rung of the ladder, more likely they would be Bubba's b***h.
• Have a good, well trained, active Safety Committee. This committee would typically have someone from each department who could report on safety issues for their department. Education is important. They need to understand the safety issues involved with the work they do so they can accurately report what needs to be corrected. Make sure whoever is in charge of maintenance is on this committee. Much of what needs to be worked on involves the maintenance department. Have the committee also trained to watch for unsafe acts of fellow employees. Ideally they would also be empowered to point out these acts as they occur, but "politics" may hinder that. So have a method for them to report these violations. It is a good idea to periodically rotate new members onto the safety committee. The good thing about this is that eventually everyone receives safety training.
• Conduct periodic inspections. When I was with Printpack the HR Manager conducted a monthly safety inspection. If you have no one trained to do this, correct it. Also, many industry associations or insurance companies will have a risk management or safety professional that can be enlisted to do annual or semi-annual inspections. Even if you have no one trained, managers and supervisors using common sense can do periodic inspections. The major issue in conducting inspections is to be committed to correcting errors found. If you don't make corrections and then later have a major loss the record of your inspections that went unheeded can work against you. A resulting "willful" violation may be the result. Also, follow up each accident with an investigation.
• Know and abide by the OSHA standards. This is particularly true of the recordkeeping and training requirements. The law requires that you keep records up to date of accidents, illnesses, lost-time injuries, and the training that people have received. If an OSHA inspector walks in the door these records are often the first thing they review. If they are not up to date you receive a violation and it goes downhill from there. OSHA Compliance Guide 18e, available from Amazon, can provide you with some guidance. Additionally, the if you belong to an industry association you may be able to get guidance specifically applicable to your company.
• TRAIN, TRAIN, TRAIN! Train your managers and supervisors, but also train your employees. The training that is necessary is not only on how to safely conduct their work, but also on what their rights and responsabilities are regarding safety. They need to know where the posters are, they need to know what they say (thus you may need to translate them) and they need to know where the OSHA 300 Log is posted. If you are ever inspected they may be asked these questions by the inspector. There are many safety regulations that require periodic training renewal, such as forklift training. Or the Hazard Communication program, which requires retraining every time a new material is added. Yeah, I know it can be a pain in the butt, however, it will save money in the long run. More importantly it may save someone's life. The result of an accident investigation makes a great training lesson.
• DISCIPLINE, DISCIPLINE. Correcting machinery issues does not eliminate safety problems. People still do stupid things. Unsafe acts need to be corrected immediately, and in some cases harshly in order to send a message. Do not let employees become habitual violaters, it will end up costing them and you in the end. I have had to pull people from machinery as a result of "short cuts" that were unsafe acts. Document these disciplinary actions.

Jared Shelly, of Human Resource Executive magazine published a post yesterday (not sure if mine on the New Sheriff in Town was the inspiration) that dealt with OSHA. If you want a further take on this you can read his post at Preparing for Stepped-Up Enforcement. 

Safety is not just for industrial sites. Office safety is critical as well. OSHA will be putting a new emphasis on ergonomics and muscular-skeletal disorders. So proper lifting, sitting and working methods are important. I have seen serious back injuries from lifting boxes and I have seen fingers cut off in papercutters. 

To conclude SAFETY IS AN ATTITUDE AS MUCH AS AN ACT. Keeping people safe is critical. There is nothing worse than having to face a family and having to explain why their loved one is hurt or not coming home. If you want to bring that home watch the news about the mine disaster. I would not want to be an executive in that company.