An effective workplace safety program requires proper job safety perfor- mance from everyone in the workplace. Leaders and managers must ensure that all employees know about the materials and equipment they use, known hazards, and how to resolve/control the hazards. Each employee needs to know that:
• No employee is expected to undertake a job until she has received job instructions on how to do it properly and is authorized to per- form that job.
• No employee should undertake a job that appears unsafe.
• You have trained your employees on every potential hazard that they could be exposed to and how to protect themselves.
You may be able to combine safety and health training with other train- ing, depending on the types of hazards in your workplace.
It’s imperative that employees really understand the information being taught. Pay particular attention to your new employees and to employees who are moving to new jobs. Train your supervisors to understand all the hazards faced by the employees and how to reinforce training with quick reminders and refreshers, or with disciplinary action if necessary. And as we discussed at the beginning of this chapter, you must communicate safety to your employees in a language they understand.
A written workplace safety program is just words on paper if you, your supervisors, and employees are not aware of it and don't understand it. Observing employees’ understanding of safe practices is a more efficient measure than employees simply telling you or saying that they under- stand.
Employees cannot follow safety rules, identify hazards, use correct work procedures or protective equipment, or work to achieve goals if they do not have the necessary knowledge to do so. Furthermore, if employees are afraid to discuss safety and health concerns with management or have no clear method of reporting their concerns to management, safety and health hazards can go undetected. Uncorrected hazards can adversely affect employee morale and productivity, even if an incident, injury, or illness does not occur as a result.
While communication regarding safety and health issues should be a continual process, there are times when it is especially critical, including:
• The beginning of an employee’s new job assignment
• Whenever material, process, or procedural changes are implemented • Whenever the employer notices deficiencies in safe work practices
Communication
Safety training should go beyond the minimum requirements set by OSHA regulations. Some key points when incorporating training are:
• Engage employees directly into the training delivery by using pictures, video, and multimedia (involving employees) to make them part of the process. It’s okay to use generic/core training materials; however, make them personal to your work environment for the best affect. • Supervisors should receive at least as much safety and health training
as front-line employees, if not more.
• The design of a training session should be based on clearly stated goals and objectives. The goals and objectives should reflect the knowledge and skills employees need to do their jobs safely and should be as specific as possible.
• Training content should be directly applicable to the hazards, proce- dures, and equipment the employees encounter on the job.
• Employees are more receptive to training if they see how they can apply the training to their work.
• Training content must cover emergency procedures as well as normal day-to-day activities.
• Because individuals learn in different ways, the variety of training methods should be used to help communicate the material to be learned. You will read in Chapter 7 that changing an employee’s role (having him or her conduct training) will positively and forever change his/her safety behavior.
• Some trainers develop games to review material, especially for re- fresher training.
• There should also be some way to check for employee understand- ing of the course content to ensure transfer of the training to the workplace. Methods often used include class discussion, written tests and quizzes, demonstrations, and on-the-job observations.
• Supervisors can lead the majority of safety training sessions; however, it’s imperative that front-line employees also lead safety meetings. • Supervisors can observe and coach their employees by correcting
unsafe work practices as they occur and positively reinforcing the use of safe work practices.
• Employees can be encouraged to work with each other to reinforce workplace safety. This is especially important when more experi- enced employees work with new employees.
• Experienced employees should teach newer employees safe work practices rather than risky shortcuts.
• Other methods of communicating job safety and health information include posters, employee handbooks, and handout materials, in- cluding one-page fact sheets or booklets, computer-based learning, and safety promotional activities.
• If posters are used, they should have a clear message and be located in areas where employees are likely to see them, such as near the time clock or in the cafeteria. It’s highly recommended that you incorporate
your employees (think of how Wal-Mart incorporates their Associates in print ads) in the posters rather than using generic “be safe” posters. With the avail- ability of digital cameras and a color printer, it’s a small investment with a big payoff. Posters should be rotated regularly.
• Relying on written materials only can be ineffective for several reasons:
• Many working adults may lack basic reading skills. To avoid embarrassment and humiliation, they will often hide this from their supervisors and coworkers. Due to the growing diversity of today’s workforce, many workers have limited English speaking and reading skills.
• It is also common for a person to set aside reading material “for later, when I have time” and never pick it up again. These prob- lems can be addressed at least partially by having the employees
complete worksheets or quizzes about the written material and submit them to their supervisor or the safety coordinator for grading.
• Increasing numbers of businesses are turning to computer-based learning as a training method. Computer-based learning can com- bine video, sound, and text in an interactive format that can test em- ployees for completion and understanding. Several standardized programs are available in this format, and many employers are devel- oping their own.
• Safety promotional activities, such as fairs, dinners, and safety stand- downs, can also be an effective method of communicating the im- portance of workplace safety to employees. Employers must be careful, however, that “incentive programs” do not send the wrong message. For example, some programs (based on the number or fre- quency of lost-time injuries) have resulted in the underreporting of injuries by employees. (See Chapter 7 for an expanded discussion on this subject.)
• One of the strongest methods of communication is by example. Managers and supervisors must model their actions for employees by working safely and following all safety and health rules.
Effective communication flows in two directions. Employees must feel free to discuss their safety concerns with their supervisors without fear of retaliation. They should know the proper procedures for reporting safety and health hazards in the workplace to get the hazards corrected or to get their questions answered. Supervisors should know whom to contact for assistance in addressing safety issues and have the authority to take appro- priate corrective action. You should work to ensure that communication is occurring on all levels of the organization.
recordkeeping
Document your activities in all elements of your workplace safety program. Essential records, including those legally required for workers’ compensa- tion, insurance audits, and government inspections, must be maintained as long as the actual need exists or as required by law. Keeping records of your activities, such as policy statements, training sessions, safety and health
meetings, information distributed to employees, and medical arrangements made, is greatly encouraged.
Maintaining essential records also will demonstrate sound business man- agement as supporting proof for credit applications, for showing “good faith” in reducing any proposed penalties from OSHA inspections, and for insurance and other audits. Good records also will aid efficient review of your current safety and health activities for better control of your opera- tions and to plan improvements.
Records of sales, costs, profits, and losses are essential to all successful businesses. They enable the owner or manager to learn from experience and to make corrections for future operations. Records of incidents, related injuries, illnesses, and property losses can serve the same purpose, if they are used in the same way. The primary purpose of OSHA-required record- keeping is to retain information about incidents that have happened to help determine the causes and develop procedures to prevent recurrences.
Injury and Illness Records
OSHA rules for recording and reporting occupational injuries and illnesses affect 1.4 million establishments. Small businesses with 10 or fewer employ- ees throughout the year may be exempt from most of the requirements of the OSHA recordkeeping rules. And some industries, such as service, finance, insurance, and real estate, may be exempt or classified as low haz- ard. Detailed information about OSHA recordkeeping rules can be found at www.osha.gov/recordkeeping/index.html.
The OSHA recordkeeping system has five steps:
Obtain a report on every injury or job-related illness requiring medical treatment (other than basic first aid).
Record each injury or job-related illness on OSHA Form 300 (Log of Work-Related Injuries and Illnesses).
Prepare a supplementary record of occupational injuries and illnesses for recordable cases on OSHA Form 301 (Injuries and Illnesses Incident Report). However, in most states, the workers’ compensation report of injury form is sufficient, so OSHA Form 301 does not have to be completed separately.
related fatalities or multiple hospitalizations that involve three or more employees.
Even if a business is exempt from routine recordkeeping requirements, it may be selected by the Federal Bureau of Labor Statistics (BLS) or a related state agency for inclusion in an annual sample survey. You will receive a letter directly from the agency with instructions, if you are selected.
In addition:
• Every year, prepare an annual summary using OSHA Form 300A (Summary of Work-Related Injuries and Illnesses). Post it no later than February 1, and keep it posted until May 1. A good place to post it is next to the OSHA Workplace Poster.
• Retain these records for at least five years.
• Periodically review these records to look for any patterns or repeat situations. These records identify an organization’s high-risk areas that may require immediate attention.
Basic OSHA recordkeeping requirements address only injuries and ill- nesses; many organizations expand their records to include all incidents, including those where no injury or illness resulted, such as near misses. This information can help pinpoint unsafe actions, conditions, and/or pro- cedures.
Safety councils, insurance carriers, private consultants, and others can assist you in instituting such a recordkeeping system.
Exposure Records and Others
In addition to injury and illness records, certain OSHA standards require records on the exposure of employees to toxic substances and hazardous exposures, physical examination reports, inspection records, safety com- mittee meeting minutes, safety training records, and employment records. As you identify hazards and hazard resolution steps, you will be able to determine whether these requirements apply to your workplace. Your records should be used in conjunction with your control procedures and with your self-inspection activity. They should not be considered merely as bookkeeping.