safety tips

Helpful tips to complete the OSHA Form 300 A Summary

November 21, 2023 By John Cambre

It’s getting close to that time of year, safety department!

The OSHA Form 300 A is the summary of work-related injuries and illnesses. It must be completed after the end of the year and summarizes the number of recordable injuries and illnesses that occurred in the previous year.

When completing your OSHA Form 300 A, which summarizes the data on the OSHA 300 log, you first want to ensure that your 300 Log form of work-related injury illnesses is complete and correct. After reviewing your OSHA Form 300 Log, take the totals from that to create the OSHA 300 A Summary.

OSHA also requires that the 300 A summary be certified with a signature from a company executive. You will need to post a 300 A summary from February 1st to April 30th of 2024 in a visible location where the company would normally post news or other information for employees.

Here are just a few comments regarding the term “posted/post/posting.” Think about how organizations share company information with employees.

When was the last time you received information from a bulletin board?

Recommendation: On February 1st of 2024, use the 300 A Summary as a tool that demonstrates management commitment. Email, yes, email a copy of the completed and signed 300 A Summary to frontline supervisors and recommend that they take a few minutes and share that information with all employees in the organization. Document it as a safety meeting.

These forms must be kept for five years. In addition, if a government representative, for example, OSHA, asks to see these forms, you must provide copies of these forms within four business hours.

Some companies are required not only to post their 300 A summary but also to submit it electronically to OSHA through the Injury Tracking application.

This final rule requirement has been updated and will be effective on 01/01/2024

Look for more information on this new and updated OSHA rule in the December 2023 Blog.

Requirement

At the end of the year, OSHA requires you to enter the average number of employees and the total hours your employees worked on the OSHA 300 A Summary.

If you don’t have these figures, here is some help to guide you in completing the information.

If you pay about the same number of employees every pay period throughout the year (e.g., about 100), then you can use that number as your annual average employment.

If the number of employees fluctuates from pay period to pay period (e.g., your business is seasonal, or your establishment grew or shrunk during the year), then you should use the formula below to calculate the employment average.

How to figure the average number of employees who work for your establishment during the year

Add up and then enter the number of employees your establishment paid in each pay period during the year. Be sure to include all employees: full-time, part-time, temporary, seasonal, salaried, and hourly.
Count and then enter the number of pay periods your establishment had during the year. Be sure to include any pay periods when you had no employees. For example, enter 26 if you have biweekly pay periods or 52 if you have weekly pay periods.
Divide the number of employees by the number of pay periods
Round the answer to the nearest next highest whole number. Write the rounded number in the blank on the 300 A Summary page marked: Annual Average Number of Employees

How to figure the total hours all employees worked

Include hours worked by salaried hourly, part-time, and seasonal workers, as well as hours worked by other workers subject to day-to-day supervision by your establishment (e.g., temporary help service workers).
Do not include vacation, sick leave, holidays, or any non-work time, even if employees were paid for it.
If your establishment keeps records on only the hours paid or if you have employees who are not paid by the hour, please estimate the hours that the employees work.

If this number isn’t available, you can use this optional guideline to estimate it.

Optional Guideline

Find the number of full-time employees in your establishment for the year.
Multiply by the number of work hours for all full-time employees in a year.
This is the number of full-time hours worked.
Then, add the number of overtime hours as well as the hours worked by other employees (part-time, temporary, seasonal).
Round the answer to the highest whole number.
Write the rounded number in the blank on the summary page marked: Total hours worked for all employees last year.

Note: Review your annual average number of employees to ensure it makes sense.

Review these questions to check yourself:

Is it about the same as the number of employees working at your establishment on any given day?
Is it bigger than your smallest number of employees in a pay period?
Is it smaller than your biggest number of employees in a pay period?

If the answer to any of those questions is no, then the calculation may be incorrect.

Note: You cannot divide the total number of W-2s by the number of pay periods to calculate average employment. You must add up the number of employees paid in each pay period and then divide that number by pay periods.

Click here for more information

Happy Posting!

The 10 Basic Principles of Safety

October 18, 2023 By John Cambre

In Dan Petersen’s book “Safety Management – A Human Approach” published in 1975 he presented ten basic principles of safety management that should be the foundation of all safety programs. However, very few organizations’ safety programs are created using these important principles.

Every operation should review these 10 basic principles of safety and incorporate them into their organization. Take it one step at a time.

Safety Principle Number One

An unsafe act, an unsafe condition, an accident: these negative events are symptoms that something is wrong in the management system.

Frank Bird’s domino theory stated that for every 600 identified unsafe acts (near misses) on average will produce one severe/catastrophic outcome.

Safety Principle Number Two

Certain sets of circumstances can be predicted to produce severe injuries. These circumstances can be identified and controlled.

Unusual, non-routine jobs
Nonproductive activities
High-energy sources
Certain construction situations

We can attack severity directly instead of merely hoping our attack on frequency will also affect severity.

OSHA’s Focus Four have not changed in over 20 years.

Falls
Struck By
Caught in Between
Electrical equipment exposures

OSHA’s Focus Four still accounts for the majority of injuries on a jobsite.

Safety Principle Number Three

Safety should be managed like any other company function. Management should direct the safety effect by setting achievable goals, planning, organizing, and controlling to achieve them.

In Frank Bird’s Dominio Theory, published in 1966 tied a workplace injury/illness to five dominoes with management being the number one domino that fails.

Safety Principle Number Four

The key to effective line safety performance is management procedures that fix accountability.

The front-line supervisor is the key person in accident prevention. Supervisors should be trained and educated in the application of safety procedures and their responsibilities to implement them.

Safety Principle Number Five

The function of safety is to locate and define the operational errors that allow accidents to occur. This function can be carried out in two ways:

By asking “why,” searching for root causes of accidents
By asking whether certain known, effective controls are being utilized

Safety representatives should be educated and trained to be coaches, not cops.

Safety Principle Number Six

The cause of unsafe behavior can be identified and classified. Some of the classifications are over-load (overexertion), improper matching of a person’s capacity with a load, traps, and the worker’s decision to take a shortcut.

Each of these causes can be controlled.

B.F. Skinner, an American behaviorist, stated that behavior that is rewarded is repeated.

Safety Principle Number Seven

In most cases, unsafe behavior is normal human behavior; it is the result of normal people reacting to their environment. Management’s job is to change the environment that leads to unsafe behavior.

Changing behavior changes culture.

According to Forbes Magazine writer Ekta Vyas, Ph.D., a member of the Forbes Human Resources Council, “All change requires leadership, and culture change is primarily about changing the basic assumptions and shared beliefs of organizational members.”

Safety Principle Number Eight

There are three major subsystems that must be dealt with in building an effective safety system: the physical, the managerial, and the behavioral.

Physical: Workers must be physically fit for duty.
Managerial: Management must be visible with the safety message.
Behavioral: Promote acceptable behavior and decrease unacceptable behavior.

Safety Principle Number Nine

The safety system should fit the culture of the organization.

Mixed messages from management and frontline supervisors create trust issues with workers.

Safety Principle Number Ten

There is no one right way to achieve safety in an organization; however, for a safety system to be effective, it must meet certain criteria. The system must:

Force supervisory performance
Involve middle management
Have top management visibly show their commitment
Have employee participation
Be flexible
Be perceived as positive

According to the Occupational Safety and Health Administration, OSHA, the idea is to begin with a basic program and simple goals and grow from there. If you focus on achieving goals, monitoring performance, and evaluating outcomes, your workplace can progress along the path to higher levels of safety and health achievement.

For a resource that supports Mr. Petersen’s Ten Principles, go to the following link: Safety Management – A safe workplace is sound business | Occupational Safety and Health Administration (osha.gov)

Be Safe!

OSHA’s Recording and Reporting Rule: How OSHA Reviews your Recordkeeping and Reporting Requirements

September 18, 2023 By John Cambre

Introduction

The requirement for private employers to record and report specific injuries and illnesses was one of the many cornerstones found in the Occupational Safety and Health Act of 1970.

In the development of the OSHA Act, congress saw a need to have employers use a system to track injuries and illnesses. In doing so, employers would have a database that could be used to address any hazards in the workplace that have gone unattended.

Excerpt from the OSHA Act: Section 8 paragraph (c) (2)

“The Secretary, in cooperation with the Secretary of Health and Human Services, shall prescribe regulations requiring employers to maintain accurate records of, and to make periodic reports on, work-related deaths, injuries, and illnesses other than minor injuries requiring only first aid treatment and which do not involve medical treatment, loss of consciousness, restriction of work or motion, or transfer to another job.”

January 19, 2001, OSHA issued an updated version of the original standard in the Federal Register.

Scenario

So, you get a text message or a call from the plant security gate or your receptionist that an OSHA compliance officer is present and asking for a company representative.

Key Point

Does the company have a policy and procedure for handling an OSHA inspection? Hopefully, they do.

After checking credentials, you and the CSHO (Compliance Safety and Health Officer) go to the conference room to begin the first phase of the inspection, the opening conference.

The CSHO explains the scope of his inspection, which is your recordkeeping and reporting of occupational injuries and illnesses. He pulls out a checklist, begins his interview, and makes his request.

Key Point

Let’s start with what prompted this inspection. Perhaps the most common reason is the result of a formal complaint from a worker. Maybe the worker was disgruntling or upset about some company work practice or had an issue with their supervisor. Still, he knows firsthand that the company has had work-related injuries and has not recorded the incident for fear of losing business with a client.

A copy of the formal complaint must be given to the employer representative at the beginning of the opening conference. If the employee requests that their name be withheld from the complaint document, then OSHA must remove their name. The CSHO is not allowed to reveal the name of the employee.

What happens next?

The CSHOs will then request copies of the following forms: 300 Log, 301 Incident Report, and the 300 A Summary for the last three years. If the forms are not readily available, the employer has four business hours to deliver them. That’s the law.

Key Point

The best-kept secret on the OSHA website is the Directive Library. A directive is an internal OSHA policy/procedure that outlines for the CSHO the steps and questions he should use during an inspection of a particular standard.

In this case, the standard, 29 CFR 1904 Recording, and Reporting Occupational Injuries and Illnesses, is the scope of the inspection. The directive that the CSHO will use is the following:

Audit and Verification Program of Occupational Injury and Illness Records | Occupational Safety and Health Administration (osha.gov)

In general, the purpose of the Recordkeeping and Reporting Directive is to guide the CSHO through the inspection process.

Along with requesting the three forms (300 Log, 301 Incident Report, and 300 A Summary), the compliance officer will request a review of the first aid log. Employers are not required to maintain a first aid log, but if the company does have one, then the compliance officer has the authority to see it. Remember, you are talking to a federal agent; perjury is a federal crime.

Requesting the first aid log is used to cross-check the entries with the 300 Log of Work-Related Injuries and Illnesses.

Next on the CSHO list

The compliance officer will request the total hours worked and the number of employees worked for each year and ask for a roster of current employees. At this point, the compliance officer will want to interview a random selection of those employees who are currently available.

Key Point

What type of question would a compliance officer ask an employee in a private interview? How about “Have you ever seen any workers get hurt here? Loaded question. Sure is. They will expand the inspection review if random sample interviews show sufficient deficiencies.

Another item on the compliance officer’s checklist is the worker compensation case list. Why? This is another cross-check process. Comparing the worker comp cases against the 300 Log of Work-Related Injuries and Illnesses entries.

The compliance officer will check if the establishment has an on-site medical facility and where the nearest emergency room is where employees may be treated. Can he interview the doctor? The answer is yes, he can.

By the way, the compliance officer will come with a medical access order document. This means they can review recordable case information classified as a “privacy case.”

The compliance officer will want to personally interview the person who oversees the maintenance of the OSHA injury and illnesses forms. Does the company have a designated recordkeeper?

Key Point

What are the potential citations?

Where no records are kept, and there have been injuries or illnesses that meet the requirements for recordability, as determined by other records or employee interviews, a citation for failure to keep records will generally be issued.

When the required records are kept but no entry is made for a specific injury or illness that meets the requirements for recordability, a citation for failure to record the case will typically be issued.

A citation will not be issued when no records are kept, and employee interviews have determined no injuries or illnesses.

Upon completion of the inspection (the closing conference), the CSHO will review and note the meeting findings in his case file.

For more information on this topic: Recordkeeping – Overview | Occupational Safety and Health Administration (osha.gov)

OSHA’s Recording and Reporting Rule: What You Need to Know

August 16, 2023 By John Cambre

Osha Recordkeeping – Part 1

The requirement for private employers to record and report certain injuries and illnesses was one of the many cornerstones found in the Occupational Safety and Health Act of 1970.

In the development of the OSHA Act Congress saw a need to have employers use a system to track injuries and illnesses. In doing so, employers would have a database that could be used to address any hazards in the workplace that have gone unattended.

Excerpt from the OSHA Act: Section 8 paragraph (c) (2)

“The Secretary, in cooperation with the Secretary of Health and Human Services, shall prescribe regulations requiring employers to maintain accurate records of, and to make periodic reports on, work-related deaths, injuries, and illnesses other than minor injuries requiring only first aid treatment and which do not involve medical treatment, loss of consciousness, restriction of work or motion, or transfer to another job.”

Updated Version in 2001

On January 19, 2001, OSHA issued an updated version of the original standard in the Federal Register.

The final rule contains provisions mandating the recording of work-related injuries and illnesses that must be entered on the OSHA 300 (Log) and 301 (Incident Report) forms.

It sets out the recording requirements that employers are required to follow in recording cases.

The final rule also mandates that each employer who is required by OSHA to keep records must record each fatality, injury, or illness that is work-related, is a new case and not a continuation of an old case, and meets one or more of the general recording criteria:

Death
Days Away from Work
Restricted Work Activity (commonly called “light duty”)
Transfer to another job (yes, this is recordable!)
Other recordable (like hearing loss or one stitch to the finger)

The updated standard contains a table that points employers and their recordkeepers to the various sections of the rule that determine which work-related injuries and illnesses are to be recorded.

These sections lay out the requirements for determining whether an injury or illness is work-related, if it is a new case, and if it meets one or more of the general recording criteria. In addition, the table contains a row addressing the application of these and additional criteria to specific kinds of cases (needlestick and sharps injury cases, tuberculosis cases, hearing loss cases, medical removal cases, and musculoskeletal disorder cases).

OSHA Reporting Decision Tree

The following is a decision tree, or flowchart, that shows the steps involved in determining whether a particular injury or illness case must be recorded on the OSHA forms.

Key Point

What are the OSHA reporting requirements the employer must comply with? This part of the OSHA rule was updated on September 18, 2014.

All employers are required to notify OSHA when an employee is killed on the job or suffers a work-related hospitalization, amputation, or loss of an eye.
A fatality must be reported within 8 hours.
An in-patient hospitalization, amputation, or eye loss must be reported within 24 hours.

Be prepared to supply the following information when reporting: Business name; names of employees affected; location and time of the incident, brief description of the incident; contact person; and phone number.

So, when do the eight hours start? The OSHA requirement seems a little vague. Here is a recommendation. Use the death certificate as a legal time of death.

All employers should have a policy and procedure that outlines what to do if a fatality occurs in their organization. Using a death certificate as a legal time of death is a good point to add to the policy. Also, as an employer, you have 8 hours to report. Use this time to do your investigation, get all the details, and report 7.5 hours after the incident.

Do I have to report the fatality, in-patient hospitalization, amputation, or loss of an eye if it resulted from a motor vehicle accident on a public street or highway?

If a motor vehicle accident occurs in a construction work zone, you must report the fatality, in-patient hospitalization, amputation, or loss of an eye.

If a motor vehicle accident occurred on a public street or highway but not in a construction work zone, you do not have to report the fatality, in-patient hospitalization, amputation, or loss of an eye to OSHA. However, the fatality, in-patient hospitalization, amputation, or loss of an eye must be recorded on your OSHA injury and illness records if you are required to keep such records.

Be aware that some cases that are not reportable may still be recordable.

For more information, go to this link: 1904.39 – Reporting fatalities, hospitalizations, amputations, and losses of an eye as a result of work-related incidents to OSHA. | Occupational Safety and Health Administration

Key Point

Are there exceptions to the recording of a work-related injury or illness?

This becomes interesting. If a worker is hurt at work but the review of the injury or illness falls into one of the following exceptions, the employer does not have to record the incident.

Here they are:

You are not required to record injuries and illnesses if…

At the time of the injury or illness, the employee was present in the work environment as a member of the general public rather than as an employee.
- Example: The worker is there to pick up their check and is not scheduled to work that shift.
The injury or illness involves signs or symptoms that surface at work but result solely from a non-work-related event or exposure that occurs outside the work environment.
- Example: a heart attack at work due to a lifestyle issue.
The injury or illness results solely from voluntary participation in a wellness program or in a medical, fitness, or recreational activity such as blood donation, physical examination, flu shot, exercise class, racquetball, or baseball.
The injury or illness is solely the result of an employee eating, drinking, or preparing food or drink for personal consumption (whether bought on the employer’s premises or brought in).
- For example, if the employee is injured by choking on a sandwich while in the employer’s establishment, the case would not be considered work-related.
- Note: If the employee is made ill by ingesting food contaminated by workplace contaminants (such as lead) or gets food poisoning from food supplied by the employer, the case would be considered work-related.
The injury or illness is solely the result of an employee doing personal tasks (unrelated to their employment) at the establishment outside of the employee’s assigned working hours.
The injury or illness is solely the result of personal grooming, self-medication for a non-work-related condition, or is intentionally self-inflicted.
- For example: an employee gets mad at the potato chip vending machine and breaks the glass to get his bag of chips. The injury was a severe laceration to the hand and forearm, requiring sutures (stitches). And yes, it’s not recordable.

The injury or illness is caused by a motor vehicle accident and occurs on a company parking lot or company access road while the employee is commuting to or from work.
- Note: There are two commutes a day: from your home to your first business stop and from your last business stop to your home. Injuries and illnesses that happen during the commute are not recordable.
The illness is the common cold or flu (note: contagious diseases such as tuberculosis, brucellosis, hepatitis A, or plague are considered work-related if the employee is infected at work).
The illness is a mental illness. Mental illness will not be considered work-related unless the employee voluntarily provides the employer with an opinion from a physician or other licensed healthcare professional with appropriate training and experience (psychiatrist, psychologist, psychiatric nurse practitioner, etc.) stating that the employee has a mental illness that is work-related.
- Example: Your boss drove you crazy.

Stay tuned for more.

Osha Record-keeping Requirements: I hate paperwork! Don’t you?

July 18, 2023 By John Cambre

The simple answer is yes! But when it comes to the Federal government rules, paperwork is still a requirement.

Even a small business can be required by the Department of Labor/OHSA to keep certain records required by regulations.

Let us start with the OSHA Code of Federal Regulation (CFR) Part 1904 Recording and Reporting Occupational Injuries and Illnesses. The OSHA recording and reporting rule had a major update in 2001. And had another update in 2020.

The rule applies to all private employers (unless exempted see link in article) and public entities in some state OSHA programs.

Three OSHA recordkeeping forms are required to be kept in writing if your company has more than ten full time employees (temporary labor that you supervise on a day-to-day basis count as an employee).

The forms, 300 Log, 301 Incident Report, and the 300 A Summary, are required to be maintained for five years. These forms are required to be completed when ever an employee has experienced a work-related injury or illnesses that meets the recordable criteria. Once the recordable incident has taken place the employer has 7 calendar days to record the incident on the form 300 Log of Work-Related Injuries and Illnesses.

In addition to the Form 300 Log entry, the employer is also required to complete form 301Injury and Illness Incident Report. The 301 describes the recordable injury or illness in detail.

If there is an OSHA visit by a compliance officer, the officer will ask to see the last three years of these forms. This is a common procedure that takes place during the opening conference. By the way if the employer cannot readily produce the forms in that meeting, the company has four business hours to produce them.

If the injury or illnesses recordable meets the definition of a “privacy case,” the employer is required to keep a separate confidential 300 log and 301 incident report. There should be procedures in place to protect that information within the company.

One note about keeping the required injury and illness forms. As a company you may be exempt from keeping them if you are listed as a low hazard industry.

This exemption if based on your North American Industrial Classification System business code (NAICS).

From the OSHA website:

Non-Mandatory Appendix A to Subpart B — Partially Exempt Industries

Employers are not required to keep OSHA injury and illness records for any establishment classified in the following North American Industry Classification System (NAICS), unless they are asked in writing to do so by OSHA, the Bureau of Labor Statistics (BLS), or a state agency operating under the authority of OSHA or the BLS. All employers, including those partially exempted by reason of company size or industry classification, must report to OSHA any workplace incident that results in a fatality, in-patient hospitalization, amputation, or loss of an eye (see § 1904.39). The list of partially exempt industries is based on the 2007 NAICS codes. If an industry listed on the “Non-Mandatory Appendix A to Sub part B – Partially Exempt Industries” no longer exists in the 2017 and 2022 NAICS coding system, this would not change your partially exempt status.

Recordkeeping – Non-Mandatory Appendix A to Subpart B — Partially Exempt Industries | Occupational Safety and Health Administration (osha.gov)

Final note on CFR 1904. The three forms can be on your computer system.

Here is a link to the forms with directions: OSHA Forms for Recording Work-Related Injuries and Illnesses

Next, the bloodborne pathogen rule, OSHA 29 CFR 1910.1030.

This standard governs the requirement to maintain a recording of all needlesticks injuries. The standard applies mostly to the medical field or to any company that may have a potential exposure to contaminated needlesticks and or blood and bodily fluids. The employer must maintain a sharps injury log unless it is exempt under Part 1904 — Recording and Reporting Occupational Injuries and Illnesses. (See the above link)

The term sharps refer to needlesticks. Employees who have experienced an accidental needlestick to any part of their body have a potential to contract an illness. The employer is required to record that incident on the 300 Log as an injury. If the employee is diagnosed thru testing and has contracted a disease the employer must go back to the 300 Log and reclassify the injury as an illness.

Employees who have had exposure to a splash of blood or any potentially infectious material must record the incident on the 300 Log as a privacy case.

The next required OSHA paperwork pertains to medical records.

The standard, OSHA CFR 1910.1020 Access to employee exposure and medical records. , has been around since 1996 and was updated in 2011. Briefly, this OSHA standard is applicable when an employer is required to submit the employee to a medical test to record some aspect of health exposure. At that point, the test becomes a medical record and is required to be kept by the employer for the employee’s length of employment and an additional 30 years. Yep, 30 years.

What other OSHA standards apply to this standard?

Let us start with the two most common standards: OSHA CFR 1910.134 Respiratory Protection and OSHA CFR 1910.94 Hearing Conservation Program.

The respiratory standard requires each employee who are required to wear a respirator (definition of respirator):

Air-purifying respirator means a respirator with an air-purifying filter, cartridge, or canister that removes specific air contaminants by passing ambient air through the air-purifying element.

Atmosphere-supplying respirator means a respirator that supplies the respirator user with breathing air from a source independent of the ambient atmosphere and includes supplied-air respirators (SARs) and self-contained breathing apparatus (SCBA) units.

to complete a required medical evaluation by a licensed health care professional. Here is a link to form:

1910.134 App C – OSHA Respirator Medical Evaluation Questionnaire (Mandatory). | Occupational Safety and Health Administration

That medical evaluation is a medical record.

The second standard, Hearing Conservation Program, requires the employer in general industry only (does not apply to construction) to conduct a baseline hearing test for each employee upon entering the company and to conduct a required annual audiometric hearing test to compare to the baseline.

The test is required for employees who will have a potential exposure to noise at or above 85 decibels measured on an 8-hour time weighted average.

Other standards that fall under the medical records requirements are just to name a few:

CFR 1910.1001 Asbestos

CFR 1910.1025 Lead

CFR 1910.1028 Benzene

CFR 1910.1048 Formaldehyde

CFR 1910.1052 Methylene Chloride

CFR 1910.1053 Respirable Crystalline Silica

Good luck with keeping those records. For more information, please see www.osha.gov.

Simple but not Easy: Part 3

June 21, 2023 By John Cambre

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.”

Source: https://www.osha.gov/safety-management

Here are the seven core steps:

Management Leadership
Worker Participation
Hazard Identification and Assessment
Hazard Prevention and Control
Education and Training
Program Evaluation and Improvement
Communication and Coordination for Host Employers, Contractors, and Staffing Agencies

Part 3 Starts Here.

6. Program Evaluation and Improvement

It is an old statement: What gets measured gets done. The origin of the statement is up for grabs however the message is clear: when you measure a process/policy/procedure it gives you the information you need to make sure you achieve what you set out to do or fix what you are not.

So, let us clarify for a moment: Program Evaluation and Improvement = A Safety and Health Program Audit.

Once safety and health programs are established, it should be evaluated/audited initially to verify that it is being implemented as intended.

After that, employers should periodically, and at least annually, step back and assess/audit what is working and what is not, and whether the program is on track to achieve its goals.

Whenever these assessments/audits identify opportunities to improve the program, employers, managers, and supervisors—in coordination with workers—should adjust and monitor how well the program performs as a result.

Sharing the results of monitoring and evaluation within the workplace, and celebrating successes, will help drive further improvement.

Program evaluation and improvement/audit includes:

Establishing, reporting, and tracking goals and targets that indicate whether the program is making progress.
Evaluating the program initially and periodically thereafter to identify shortcomings and opportunities for improvement.
Providing ways for workers to participate in program evaluation and improvement.

Action items to accomplish the sixth step:

Action item 1: Monitor performance and progress

Action item 2: Verify the program is implemented and is operating

Action item 3: Correct program shortcomings and identify opportunities to improve

Be aware of bad audits. Never accept an auditor’s recommendations unless the recommendation can be established using a standard or an existing directive as a comparison. Opinions are, well, opinions.

One of the best kept secrets on the OSHA website is the OSHA Directive Library. An OSHA Directive is an internal document that is available to the public but was written as a guide for the OSHA Compliance Officer during an inspection. They can be an excellent source for creating an evaluation/audit.

Here are links to resources the organization should consider accomplishing this step:

OSHA Directives:https://www.osha.gov/enforcement/directives/directivenumber/CPL

Welcome to the Safety Climate – Safety Management Information System (SC-SMIS) https://www.scsmis.com/

7. Communication and Coordination for Host Employers, Contractors, and Staffing Agencies

There must be a system for vetting subcontractors. If not, it can lead to OSHA citations

and expensive legal defenses. Past OSHA cases demonstrate how this can easily

happen if you do not have a process in place to ensure subcontractors have the skills and

experience to get the job done safely. Increasingly general contractors are using

online services to check the safety and OSHA history of subcontractors.

In today’s economy, an increasing number of workers are assigned by staffing agencies to work at specific host worksites under the direction and control of the host employer.

Examples include seasonal workers, such as delivery drivers and warehouse workers, who may be placed in both short- and long-term assignments. In these situations, it is important for the staffing agency and the host employer to communicate and coordinate to provide and maintain a safe work environment for their workers.

In other situations, some workers are employed by a host employer and others by a contractor or subcontractor.

Examples include electrical or mechanical contractors working in a facility, a vendor installing or maintaining equipment, or long-term contractors providing building cleaning and maintenance.

OSHA refers to these as “multi-employer” worksites. In these circumstances, it is important that each employer and contractor consider how its work and safety activities can affect the safety of other employers and workers at the site.

In both temporary worker and multiemployer situations, safety is enhanced if employers establish mechanisms to coordinate their efforts and communicate effectively to afford all workers equal protection against hazards. These mechanisms include measures to ensure that all workers on site (and their representatives) can participate in preventing injuries and illnesses.

Failure to take these steps may undermine safety programs. For example, if the different employers have inconsistent policies for when and where to wear personal protective equipment, workers may mistakenly believe that the equipment is not needed, leading to injury.

Inconsistent safety policies may also cause workers to question the credibility of safety and health programs, resulting in less meaningful employee engagement and participation.

Effective communication and coordination among such employers mean that, before coming on site, contractors and staffing agencies and their workers are aware of:

The types of hazards that may be present.
The procedures or measures they need to use to avoid or control their exposure to these hazards.
How to contact the host employer to report an injury, illness, or incident or if they have a safety concern.

It also means that host employers and their workers are aware of:

The types of hazards that may arise from the work being done on site by workers employed by contractors or staffing agencies.
The procedures or measures needed to avoid or control exposure to these hazards.
How to contact the contract or staffing firm if they have a safety concern.
What to do in case of an emergency.

Action items to accomplish the seventh step:

Action item 1: Establish effective communication

Action item 2: Establish effective coordination

Here are resources the organization should consider accomplishing this step:

Multi-Employer Policy 1999 https://www.osha.gov/enforcement/directives/cpl-02-00-124

https://www.osha.gov/publications/bytopic/safety-and-health-programs

Temporary Employees: https://www.osha.gov/publications/bytopic/temporary-workers

Temporary Employees: https://www.osha.gov/temporaryworkers

Owners, managers, supervisors, and workers all need to understand the safety and health program’s structure and goals.

Having this knowledge and a plan to implement ensures that everyone can fully participate in the company’s safety and health workplace culture.

End of Simple But Not Easy.