Simple But Not Easy | Part 1

Are you starting or revamping an occupational safety and health program? Well, here is some good advice: The steps are simple, but the process is not easy.

In November of 2016 the Occupational Safety and Health Administration, OSHA, issued an updated Recommended Practices for Safety and Health Programs. The last time OSHA issued recommendations for establishing a safety and health program was 1989.

The new recommendations give employers an excellent blueprint on starting and maintaining an occupational safety and health program.

“The Recommended Practices are designed to be used in a wide variety of small and medium-sized business settings. The Recommended Practices present a step-by-step approach to implementing a safety and health program, built around seven core elements that make up a successful program.”


Here are the seven core steps to start a safety program:

  1. Management Leadership
  2. Worker Participation
  3. Hazard Identification and Assessment
  4. Hazard Prevention and Control
  5. Education and Training
  6. Program Evaluation and Improvement
  7. Communication and Coordination for Host Employers, Contractors, and Staffing Agencies

1. Management Leadership

This is perhaps the most difficult step. 

Management provides the leadership, vision, and resources needed to implement an effective safety and health program. Management leadership means that business owners, managers, and supervisors:

  • Make worker safety and health a core organizational value.
  • Are fully committed to eliminating hazards, protecting workers, and continuously improving workplace safety and health.
  • Provide sufficient resources to implement and maintain the safety and health program.
  • Visibly demonstrate and communicate their safety and health commitment to workers and others.
  • Set an example through their own actions.

Action Items to accomplish the first step.

Action item 1: Communicate your commitment to a safety and health program.
Action item 2: Define program goals.
Action item 3: Allocate resources.
Action item 4: Expect performance.
Action item 5: Communicate your commitment to a safety and health program.

A clear, written policy helps you communicate that safety and health is a primary organizational value –as important as productivity, profitability, product or service quality, and customer satisfaction.

2. Worker Participation

Workers need to be involved.

To be effective, any safety and health program needs the meaningful participation of workers and their representatives. Workers have much to gain from a successful program and the most to lose if the program fails. They also often know the most about potential hazards associated with their jobs. Successful programs tap into this knowledge base.

Worker participation means that workers are involved in establishing, operating, evaluating, and improving the safety and health program. All workers at a worksite should participate, including those employed by contractors, subcontractors, and temporary staffing agencies.

In an effective safety and health program, all workers:

  • Are encouraged to participate in the program and feel comfortable providing input and reporting safety or health concerns.
  • Have access to information they need to participate effectively in the program.
  • Have opportunities to participate in all phases of program design and implementation.
  • Do not experience retaliation when they raise safety and health concerns; report injuries, illnesses, and hazards; participate in the program; or exercise safety and health rights.

Action Items to accomplish the second step.

Action item 1: Encourage workers to participate in the program.
Action item 2: Encourage workers to report safety and health concerns.
Action item 3: Give workers access to safety and health information.
Action item 4: Involve workers in all aspects of the program.
Action item 5: Remove barriers to participation.

3. Hazard Identification and Assessment

Hazard recognition is a key component.

One of the “root causes” of workplace injuries, illnesses, and incidents is the failure to identify or recognize hazards that are present, or that could have been anticipated. A critical element of any effective safety and health program is a proactive, ongoing process to identify and assess such hazards.

To identify and assess hazards, employers, and workers:

  • Collect and review information about the hazards present or likely to be present in the workplace.
  • Conduct initial and periodic workplace inspections of the workplace to identify new or recurring hazards.
  • Investigate injuries, illnesses, incidents, and close calls/near misses to determine the underlying hazards, their causes, and safety and health program shortcomings.
  • Group similar incidents and identify trends in injuries, illnesses, and hazards reported.
  • Consider hazards associated with emergency or nonroutine situations.
  • Determine the severity and likelihood of incidents that could result for each hazard identified and use this information to prioritize corrective actions.

Some hazards, such as housekeeping and tripping hazards, can and should be fixed as they are found. Fixing hazards on the spot emphasizes the importance of safety and health and takes advantage of a safety leadership opportunity.

Action Items to accomplish the second step.

Action item 1: Collect existing information about workplace hazards.
Action item 2: Inspect the workplace for safety hazards.
Action item 3: Identify health hazards.
Action item 4: Conduct incident investigations.
Action item 5: Identify hazards associated with emergency and nonroutine situations.
Action item 6: Characterize the nature of identified hazards, identify interim control measures, and prioritize the hazards for control.

So, why is it not easy? One reason is that the value an organization puts on safety is rarely as important as the values an organization puts on cost, quality, and production.

Other critical barriers that make this process not so easy: 

  • Labeling safety and health elements as “programs.” Safety programs, like television programs, have a start and finish. 
  • A better alternative is to think of safety as a process versus a program.
  • Compliance with federal standards is important, but it’s not necessarily the answer. OSHA is under staffed and operates on a budget less than most federal agencies.
  • It seems that OSHA’s fundamental principle is “accidents are caused by things, not by people”.
  • We think of safety professionals as managers versus leaders of a process.

Stay tuned for Part 2.

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