it must know how its program is structured and why it was so structured when it was first developed. We ask a few moments of patience as we explain several critical concepts, as we feel they will assist greatly in:
• Analyzing your program as it exists today
• Recognizing where improvements must be made
• Deploying a workplace safety program that has within it elements that are focused on the recognition of actual hazards, from both unsafe acts and conditions, and how best to control them
There has been a fundamental shift in what workplace safety programs are called. Some are referred to as injury and illness prevention programs, while others, especially historically, have been referred to as safety pro- grams or accident prevention programs. What does this have to do with taking stock of where you are? You might be wondering.
Understanding what programs are called has everything to do with how an organization develops (writes, if you will) its workplace safety program and
subsequently analyzes its effectiveness and other important characteristics, such as regulatory compliance. In addition, the program’s name (title) plays a considerable role in the robustness and focus of an organization’s plans.
The shift in terminology is certainly touched by a bit by academia, but as authors and teachers, we’re okay with that. As practicing safety and health professionals, however, we also know that we have to find the prac- tical discussion that works within industry and allows you, the person responsible for workplace safety, to recognize the value of what we’re say- ing. In addition there is a practical aspect—that is, bettering your safety and health efforts by referring to your plan in a way that is meaningful to your company.
From the academic perspective, some of the changes in how safety pro- grams are named have been based on research and the findings of those within the academic community. Other changes have been an outcome of the efforts of practitioners, and still other names come from terminologies contributed by the regulatory agencies that oversee safety and health per- formance within the business environment.
Twenty-five to thirty years ago, most plans were referred to as accident prevention plans. If you believe the definition of the word accident (a sud- den, unforeseen event), then you will be able to recognize the hurdles peo- ple faced managing a program based around events that can’t be explained. In the late 1960s and early 1970s, the term safety programs became com- mon. This change occurred because the field was growing and the number of practitioners within workplace safety was increasing; many were tasked with the development of plans and programs. In many cases, effectiveness (at the time measured in reduced injuries and illnesses) was not the first measure of success.
Safety programs often focused on acute events that led to injuries and ill- nesses. This did not coincide with an ever-increasing understanding of the cumulative nature of some injuries and the fact that the practices of indus- trial hygiene and occupational medicine were hitting their strides. It would be nearly 20 years before there was significant focus on the fact that many processes resulted in not just injuries but illnesses as well, including those that were psychological (e.g., stress) or psychosocial (for example, some adverse outcomes from ergonomic-related stressors).
programs (IIPP). Use of the term IIPP suggests that both injuries and ill-
nesses must be given equal consideration in programs focused on the wel- fare of workers. No longer are causes for any adverse outcome accepted as unknown (accidental). The outcomes are either injuries or illnesses, and they must develop from recognized exposures, whether physical, chemical, biological, ergonomic, or psychological.
Whether you title your program accident prevention, safety, safety and health, injury and illness prevention, or workplace safety, the reality is that it doesn’t matter, unless there is a regulatory mandate to do so (which does exist in some states). What does matter is that your efforts recognize unsafe actions and conditions that contribute to both injuries and illnesses.
To summarize:
• Your workplace safety programs must recognize your employees’ actual exposures.
• The program you develop must be capable of mitigating those expo- sures and ultimately the injuries and illnesses that may occur. • Your analysis, regardless of the methodology employed, must be
capable of analyzing exposures and outcomes.
As we move through this chapter and we refer to workplace safety pro- grams, we ask that you think in terms of injury and illness prevention.
why workplace safety programs
?Thinking of your workplace safety program as an IIPP forces you into con- sidering the exposures that result in both injuries and illnesses. Thus, when you begin taking stock of where your program is in its development and effectiveness, your analysis will be sufficiently robust.
From a workplace safety program perspective, you will be analyzing sev- eral critical characteristics and the capabilities of your program. A good starting point, regardless of the state you work within, will be to look up the OSHA program for your state. (The state plan directory can be found at www.osha.gov/fso/osp/ or www.workplacesafetynow.com.) Some states have specific programs (state OSHA programs); for other states, the federal OSHA (Fed/OSHA) program has been adopted or is in effect. Reviewing the applicable OSHA requirements will provide a fine baseline
for you, but additional analysis is almost always required. In general, how- ever, you will begin your analysis by looking at specifics within these gen- eral categories:
• Your organization’s policy statement regarding safety and health management, including identification of responsible personnel • Hazard recognition and resolution activities
• General rules and regulations or code of safe practices (specific safety codes and standards) that are operation- and hazard-specific
• Workplace safety communications
• Methods to evaluate, maintain, and improve your safety and health efforts and ensure compliance with your plan, including disciplinary capabilities
• Training and education programs that specifically support assisting employees in understanding the codes of safe practices, their roles and responsibilities toward safety, and the ramifications—from an injury development and administrative perspective—if they don’t observe the practices (e.g., discipline)
• Tools required to manage safety and your program efforts, including recordkeeping
The fact that you have a workplace safety program is not an end all. It’s what you accomplish with your safety program that makes all of the differ- ence. Let’s talk about some of the factors essential to workplace safety pro- grams that should be kept in the forefront of your analytical efforts. These are the broad-scoped aspects (quantitative) of your analysis. We provide a program-specific example in this and the next chapters.
Quantitative Review Categories: Start Big!
• Do you have to have a workplace safety program? The easy answer is yes—
every company needs a workplace safety program, but its detail and recordkeeping requirements may vary. OSHA may allow written plan exemptions (as for employers with a small number of employees or those in some non–high-hazard business sectors). Regardless of these exemptions, all employers should have a written plan. Some will be more comprehensive than others. From our perspective the safety and
health of employees is too important to “wing it.” OSHA provides sample programs for low-hazard employers with few employees that can help with program development (as long as specific hazard and operational modifications are incorporated). The answer to whether you must have a workplace safety program or plan is a simple one. Plan format and structure may be a bit tougher to analyze, however; we provide more detail on the structure in the following chapters. • Is your plan in the proper form or format? Your plan should be in writ-
ing and, where necessary, it must be in languages or formats that all employees can understand. We’ve been to companies where plans were produced in English, Spanish, Tagolog, Hmong, Vietnamese, and Chinese, for example. If people are valued enough to be hired, then they should be valued enough to communicate with effectively. Does your plan provide for effective communication?
• Do you understand or recognize the class of business you are in? This is crit-
ical. Programs that are written for high-hazard operations, such as agriculture, construction, transportation, and many others, often must meet some specific requirements in their plan design, structure, and deployment. Make sure you know where you stand on this issue. Both Fed/OSHA and state OSHA programs define high-hazard industries. You can base some of the intricacies of your plan on these requirements. For example, there are specific requirements in addi- tion to general industry standards for agriculture, construction, trans- portation, pressure vessels, elevators, and many more; your workplace safety program must be capable of recognizing the standards that apply and then integrating the proper general and specific industry safety practices.
• Do you have the most frequent regulatory citations in mind as you develop your plan? If you study and recognize the most frequent citations
(published annually by the OSHA programs, the National Safety Council, some chambers of commerce, the Bureau of Labor Statistics, and other sources), then you will do a much better job of focusing your program efforts. Do you conduct this review? Some of the more common citations include no written workplace safety program, electrical hazards, recordkeeping violations, respiratory protection plan violations, and the lack of emergency action plans.
You can use this information to assist your organization in auditing and evaluating the safety and health function.
• Is your workplace safety program sufficiently robust? There is no one-size-
fits-all plan. Certainly you’ve inferred that from previous comments. Merely having a written workplace safety program does not provide any guarantees that injuries and illnesses will be controlled, especially when hazard-specific codes of safe practice are missing. Your pro- gram must respond to the operations of your company and the haz- ards that are present. You may have only a few employees, but if these workers are steeplejacks, then your workplace safety program must be capable of addressing working at heights, fall protection, weather and temperature stresses, personal protective equipment, and many more considerations. The point here is that the fact that you have some written safety provisions should not give you total comfort. You must dig further and be certain that your plan can and does respond, through hazard recognition and control, to the actual haz- ards your employees face in their day-to-day tasks. Pound this point home every chance you get.
• Do you recognize when your plans or workplace safety program should be reviewed and updated? There are several ways to ensure that your plans
are reviewed. One is simply to schedule annual reviews. However, other dynamics are indicative of the need to review your plan and ensure that it is current and effective. Some of the dynamics that stimulate these reviews include:
• Scheduled reviews and audits • Changes in operations
• Injury and illness trends: Is the plan reflective of how employees are becoming injured or ill?
• New laws and regulations
• New processes, materials, and equipment
• Information provided by a worker, supervisor, or manager There may be other triggers as well. Once they are identified, they should be added to your trigger list and, where necessary, be utilized to update your program.
These “big” categories are designed to get you to begin taking stock of where you are and where your program is in terms of its ability to assist in reducing injuries and illness, save the organization time, effort, and money, and assist with regulatory compliance.
Goals of Your Initial Assessment
The Society for Human Resources Management in a 2002 publication noted three specific and meaningful goals (paraphrased here) that OSHA has included in their efforts. It is worthwhile to reiterate these goals as you review or update your own plan:
Goal 1. Improve workplace safety and health for all workers, as evidenced by fewer hazards, reduced exposures, and fewer injuries, illnesses, and fatalities.
Goal 2. Change the workplace culture to increase employer and worker awareness of, commitment to, and involvement with safety and health. Toward this end, OSHA will make all standards, regulations, and reference materials available on the OSHA Web site.
Goal 3. Secure public confidence through excellence in the development and delivery of OSHA’s programs and services.