OSHA has long been pushing to
set a requirement for businesses to have written safety & health
programs. They have even provided sample programs for areas such as
confined space safety. Developing a series of comprehensive and
effective safety program that combine to become your company safety
manual is not as difficult as it may seem at the outset. As with any
project, you must develop a frame work that defines the scope of the
task. With today's computers, word processing programs and the wealth
of information that can be cut, pasted and edited, you don't have to
start from scratch. Start by getting a copy of the OSHA standard and
all applicable industry or ANSI standards.
The framework - almost
every safety programs can be written with the same outline. For
example:
Purpose
Policy
Responsibilities
Training
Recordkeeping
Audits & Inspections
Hazards
Hazard Controls
Rules & Procedures
Program Purpose - a
short statement that answers the question "Why do we have this
program?" Be clear and concise and use plain language that everyone
will understand.
Example from a Confined
Space Program: The Confined Space Entry Program is provided to
protect authorized employees that will enter confined spaces and may
be exposed to hazardous atmospheres, engulfment in materials,
conditions which may trap or asphyxiate due to converging or sloping
walls, or contains any other safety or health hazards. Reference:
OSHA-Permit-Required Confined Spaces (29 CFR 1910.146).
Policy - short statement
of company policy that coveys managements support and intentions of the
specific program.
Example from an Asbestos
Control Program: It is the policy of [COMPANY] that only
qualified employees are allowed to conduct any asbestos repairs,
maintenance or removal. All unqualified employees must be protected
from exposure to asbestos fibers by isolating and controlling access
to all affected areas during asbestos work. All tasks involving the
disturbance of asbestos containing material will be conducted only
after appropriate work controls have been identified and implemented.
A qualified supervisor shall be available at asbestos controlled work
sites during all activities. Proper personal protective equipment,
vacuums and filters must be used and properly maintained. If outside
contractors are employed in any asbestos related work, company
management must ensure that the contractor used proper procedures, all
contractor employees have been properly trained and that proper
equipment and protective gear are used.
Responsibilities - this section allows you to specifically
spell out who is responsible for what parts of the program. Everyone
has a part to play: management, supervisors and employees. Some
programs will have specific responsibilities for specific management
positions, such as the Respiratory Protection or Ergonomic Program
Administrators.
Example from a Fire Prevention Program
Management
-
Ensure all fire
prevention methods are established and enforced
-
Ensure fire suppression
systems such as sprinklers and extinguishers are periodically
inspected and maintained to a high degree of working order
-
Train supervisors to
use fire extinguishers for incipient fires
-
Train employees on
evacuation routes and procedures
Supervisors
-
Closely monitor the use
of flammable materials and liquids
-
Train assigned
employees in the safe storage, use and handling of flammable
materials
-
Ensure flammable
material storage areas are properly maintained
Employees
-
Use, store and transfer
flammable materials in accordance with provided training
-
Do not mix flammable
materials
-
Immediately report
violations of the Fire Safety Program
Training - In this section present the training required for
managers, supervisors and employees. List the topics that must be
covered for each group. Go beyond the OSHA required training of the
standard. Ask yourself "what do I want them to be able to do and
what do I want them to know to meet the specific program goals?"
Also include the type of training such as classroom, field or on-the job
or a combination of training session types. Detail the specifics of how
often the training is to be conducted and for who. If special
qualifications are required for the person conducting the training, list
the requirements. If there are specific source material, such as an
OSHA, ANSI or Industry standard, include this in the training section.
Recordkeeping - no task is completed until the paperwork is
done. List what records are required by your programs. Identify the
specific forms and documents to be used. This includes items such as
audits, inspections and training.
Audits & Inspections - detail the specific program monitoring
procedures. Include the procedure for discrepancy correction and
program improvement. All programs should require at least an annual
review of effectiveness and hazard coverage.
Hazards - list and define the specific hazards that are
covered by the program. Include the physical areas of your facility in
which the hazards exist.
Hazard Controls - this section covers the engineering,
administrative and work practice controls used to eliminate or control
the specific program hazards.
Engineering Controls -
engineered safeguards used to protect employees by preventing exposure
to hazards. Examples of engineering controls are machine guards,
safety controls, isolation of hazardous areas, monitoring devices,
etc.
Administrative Controls
- These controls involve the use of procedures, assessments,
inspection and records to monitor and ensure safe practices and
environments are maintained. Other administrative controls are used to
identify new hazards and implement corrective action. Examples of
administrative controls are periodic inspections, equipment operating
and maintenance procedures, hazard analysis, selection and assignment
of personal protective equipment, etc.
Training Controls -
This aspect of hazard control is used to ensure employees are fully
and adequately trained to safely perform all tasks to which they are
assigned. No employee should attempt any task without proper training
in the equipment used, required personal protective equipment,
specific hazards and their control and emergency procedures. Examples
of training controls are initial new hire safety orientation, job
specific safety training and periodic refresher training.
Rules & Procedures - this is the nuts & bolts section of a
safety program. Programs such as Electrical Safety. Lockout - Tagout
and Confined Space Entry require these detailed procedures to eliminate
ant doubt as to the steps required for safe performance. Some programs
lend themselves to Standard Operating Procedures (SOPs), while some need
only general guidelines.
Don't forget the Forms & Documents - any recordkeeping or
management activity required by the program will need some type of
document that either records the accomplishment of a program task or
provides guidance for a task. Keep forms and documents as simple as
possible. Don't require information that is not essential to the
purpose of the form. As much as possible, provide check box choices in
the document - its easier to fill in a blank that to fill in a blank
piece of paper. Make the required information flow a logical
progression and easy to understand.
More left to do - after a program is written and all
supporting documents and forms have been developed, its time to take it
our for a spin. Provide copies to all affected managers and supervisors
and ask for their comments and concerns. Incorporate their suggestions
if they provide clarity or specific you have forgotten.
Still more ahead - each program will require training support
in the form outlines, handouts and training aids. You may also need to
conduct some train the trainer sessions to ensure supervisors can
adequately train their assigned employees.
More detailed
information and topic specific
written safety programs are in the Members Area
