INTRODUCING OSHA’S SAFETY AND HEALTH PROGRAM MANAGEMENT GUIDELINES
How can you increase worker protection, cut business costs, enhance productivity, and improve employee morale?
There are many ways you, as a business owner or manager, can approach this challenge. One way is by doing a better job of managing your company’s safety and health program.
No matter how sophisticated your safety and health efforts, they can always be improved. No matter how small your worksite, systematic methods for protecting workers can work for you.
The U.S. Department of Labor's Occupational Safety and Health Administration (OSHA) is convinced that effective management is the key to reducing the numbers and severity of workplace injuries and illnesses. ; This means using proven methods to find and understand existing and potential hazards, and then either preventing or controlling those hazards.
OSHA's conviction is based on its experience in evaluating worksites during enforcement inspections, State-run consultation service site visits, and Voluntary Protection Programs (VPP) visits. We have learned that a direct relationship exists between effective management and low numbers and severity of injuries. We also credit good management with lower levels of work-related illness. A well-managed safety and health program prevents or controls employee exposure to toxic substances or other unhealthful conditions that can cause sickness.
OSHA's experience with the VPP since the recognition programs began in 1982 has been most compelling in showing the potential of safety and health management. Worksites meeting the VPP's program management requirements avoid 60 to 80 percent of the lost workday injuries that occur on average in their industries. Companies participating in the VPP also report improvements in employee morale, product quality, and productivity. For more information on the benefits of good safety and health program management and a method for comparing your site to others in your industry, see Appendix 1-1 and Appendix 1-2 at the end of this chapter.
The Safety and Health Program Management Guidelines, published in the Federal Register (54 FR 3908) on January 26, 1989, grew out of the VPP requirements and the safety and health program elements used by the State-run consultation services, which are geared toward small businesses. Available literature and public comment on the Guidelines during the proposal stage strongly supported OSHA's conclusion: the recommendations of the Guidelines work.
Although the Guidelines are not mandatory, OSHA urges all employers in all industries to adopt these management practices. We are confident that, with the help of the Guidelines, any company can establish a successful safety and health program that provides good worker protection from hazards.
This chapter briefly reviews each section of the Guidelines and the benefits you can expect from implementing these practices. We will be referring you to subsequent chapters for more detailed explanations of how to implement the recommendations. Many of the following chapters include tools useful in initiating or improving management systems for worker protection. The information we present is intended for the full spectrum of large and small worksites and is not dependent on any particular management style: the management principles that we outline are working across the board right now in the VPP.
The Guidelines outline a management program whose purpose is to accomplish the following: to recognize and understand all the hazards and potential hazards of the workplace; to prevent or control those hazards; and to train employees at all levels so they understand the potential hazards they may be exposed to and know how to help protect themselves and others. To accomplish this, the Guidelines are divided into four parts, what OSHA calls major elements:
- Management Leadership and Employee Involvement
- Worksite Analysis
- Hazard Prevention and Control
- Safety and Health Training.
Each element is further divided in several recommended actions.
MANAGEMENT LEADERSHIP AND EMPLOYEE INVOLVEMENT
This element describes the leadership that management provides to ensure workplace safety and health and to encourage employee involvement in protection efforts. Many of the actions listed under this element are applicable to all areas of business management. The Guidelines simply recommend you put them to use in improving worker safety and health protection. The actions cover:
- Safety and Health Policy,
- Goal and Objectives,
- Visible Top Management Leadership,
- Employee Involvement,
- Assignment of Responsibility,
- Provision of Adequate Authority and Resources,
- Accountability, and
- Program Evaluation.
SAFETY AND HEALTH POLICY. By developing a clear statement of management policy, you help everyone involved with the worksite understand the importance of safety and health protection in relation to other organizational values. By clearly communicating the policy to all employees, you ensure that no confusion will exist when a conflict arises between two of these values, such as productivity and safety or health. Here is the language of the Guidelines that describes this desired action:
State clearly a worksite policy on safety and healthful work and working conditions, so that all personnel with responsibility at the site and personnel at other locations with responsibility for the site understand the priority of safety and health protection in relation to other organizational values.
For information on and samples of worksite safety and health policies, see Chapter 2.
GOAL AND OBJECTIVES. You make your general safety and health policy specific by establishing a clear goal and objectives for your program. These set the framework for assigning responsibility. Each employee should be able to see his/her work activities in terms of moving toward the goal and achieving objectives. The language of the Guideline is:
Establish and communicate a goal of the safety and health program and objectives for meeting that goal, so that all members of the organization understand the results wanted and the measures planned for achieving them.
For examples and information on goal and objectives, see Chapter 2.
VISIBLE TOP MANAGEMENT LEADERSHIP. If employees can see the emphasis that top management puts on safety and health, they are more likely to emphasize it in their own activities. It is important for worksite managers to follow set safety and health rules and work practices scrupulously to provide an example for rank and file workers. Managers should show their involvement in other ways, as well: for example, making plant-wide safety and health inspections; personally stopping activities or conditions that are hazardous until the hazards can be corrected or controlled; personally tracking safety and health performance; and -- an essential management function -- holding managers and employees accountable for their actions. The element of management leadership also should include ensuring equal safety and health protection of any contract workers at the site. Remember: Actions speak louder than words. The language of the Guidelines is:
Provide visible top management leadership in setting up the program and ensure that all workers at the site, including contract workers, are provided equally high quality safety and health protection, so that all will understand that management’s commitment is serious.
For further information, see Chapter 3.
EMPLOYEE INVOLVEMENT. The best worker safety and health protection occurs where everyone at the worksite shares responsibility for protection. For that to happen, all employees must know that they are helping to shape the program. Employees at all levels should be actively involved in finding and correcting safety and health problems. This does not mean the employer gives up responsibility and authority. The Occupational Safety and Health Act places responsibility for worker protection from occupational hazards squarely on the employer. The wise employer, however, uses employees' unique knowledge and experience to help find problems and resolve them successfully. The Guidelines recommend that employers:
Provide for and encourage employee involvement in the structure and operation of the program and in decisions that affect their safety and health, so that they will commit their insight and energy to achieving the safety and health program’s goal and objectives.
For more information on employee involvement and how to initiate or improve it, see Chapter 4.
ASSIGNMENT OF RESPONSIBILITY. Everyone in the workplace should have some responsibility for safety and health. Clear assignment helps avoid overlaps or gaps in accomplishing needed activities. In particular, you should make sure that the safety/health "expert" at the worksite is not assigned line responsibility that properly belongs to line managers and supervisors. This line responsibility would include functions such as supervising and evaluating a worker's performance in areas of safety and health, providing on-the-job training in safe work practices and personal protective equipment (PPE), and encouraging worker participation in safety and health activities.
The responsibilities should flow logically from the objectives that were set to meet the overall program goal. The actual language of the Guidelines is:
Assign and communicate responsibility for all aspects of the program, so that managers, supervisors, and employees in all parts of the organization know what performance is expected of them.
For more information and examples of assigned responsibility, see Chapter 5.
PROVISION OF AUTHORITY. Any realistic assignment of responsibility must be accompanied by needed authority and adequate resources. The latter includes appropriately trained and equipped personnel as well as sufficient operational and capital funding. The language of the Guidelines is:
Provide adequate authority and resources to responsible parties, so that assigned responsibility can be met.
ACCOUNTABILITY. Once you have assigned responsibility and provided the appropriate authority and resources to individuals, you must follow up by holding these persons accountable for achieving what they have been asked to do. Accountability is crucial to helping employees understand how critical their individual performances are and to teaching them to take personal responsibility for their performance. The Guidelines recommend that employers:
Hold managers, supervisors, and employees accountable for meeting their responsibilities, so that essential tasks will be performed.
For more information on developing accountability, see Chapter 6.
PROGRAM EVALUATION. Once your safety and health program is up and running, you will want to ensure its quality. You do this by evaluating program activities and their results in relation to the established goal and objectives. During this evaluation, keep these questions in mind: "Did we get where we wanted to go?" "Did each specific activity help us get there?" The Guidelines suggest that employers:
Review program operations at least annually to evaluate their success in meeting the goal and objectives, so that deficiencies can be identified and the program and/or the objectives can be revised when they do not meet the goal of effective safety and health protection.
For more information on safety and health program evaluation and useful evaluation tools, see Chapter 12.
Worksite analysis is a combination of systematic actions that provide you with the information needed to recognize and understand the existing and potential hazards of your workplace. While these actions may appear complicated at first glance, they consist of activities that already are being performed in most workplaces. For the sake of clarity, the Guidelines differentiate these actions as follows:
- Comprehensive Hazard Identification
- Comprehensive Hazard Surveys
- Change Analysis
- Routine Hazard Analysis
- Regular Site Safety and Health Inspections
- Employee Reports of Hazards
- Accident/Incident Investigations
- Injury and Illness Trend Analysis
COMPREHENSIVE HAZARD IDENTIFICATION. There are three components of a complete hazard inventory from which a program of prevention and control can be designed. The first of these is the comprehensive survey. This is the most basic of all the tools used to establish the inventory of hazards and potential hazards at your worksite. This survey is best performed by experts from outside the worksite who have a broad-based knowledge that includes safety engineering, industrial hygiene, and in most cases, occupational medicine. After the initial survey, comprehensive surveys need to be repeated only periodically: these will enable the expert who is conducting the survey to apply new information about hazards or methods of control.
The second component of comprehensive hazard identification is change analysis. This means what its name suggests: each time there is a change of facilities, equipment, processes, or materials in your workplace, the intended change before being introduced should be analyzed for hazards. This helps you avoid exposing your workers to new hazards. You also avoid the needless expense of retrofitting controls after installation and use.
The final component of a complete hazard inventory is routine hazard analysis. The basic form of this analysis, which is useful at every type of worksite, is the job safety analysis. This analysis divides a job into tasks and steps and then analyzes the potential hazards of each step. The analysis then produces a method of prevention or control to reduce exposure. One variation that is used at worksites with highly complex hazards -- such as chemicals or nuclear energy -- is the process hazard analysis. This analysis reduces a process to its smallest elements and then identifies the hazards of these elements and devises preventive measures or controls. In rapidly changing workplaces such as construction, phase hazard analysis is another useful form of the routine hazard analysis. Here each phase of the rapidly changing work is analyzed for the new hazards it may introduce so that preventions or controls can be devised.
The language of the Guidelines follows:
So that all hazards are identified:
Conduct comprehensive worksite surveys to establish safety and health hazard inventories and update the surveys periodically as expert understanding of hazards and the methods of control in our industry change;
Analyze planned and new facilities, processes, materials, and equipment; and
Perform routine hazard analysis of jobs, processes, and/or varied phases of work as needed.
For more information and tools to help you, see Chapter 8 and OSHA Publication 3071 (Revised 1992), "Job Hazard Analysis."
REGULAR SITE SAFETY AND HEALTH INSPECTIONS. General site inspections should be performed by personnel at the worksite. These employees will need training to recognize hazards that can slip out of the controls designed to reduce employee exposure. Inspectors also should watch for hazards that may not have been identified in the comprehensive survey or uncovered by other means. The actual language of the Guidelines is:
Provide for regular site safety and health inspections, so that new, recurring, or previously missed hazards and failures in hazard controls are identified.
EMPLOYEE REPORTS OF HAZARDS. A successful safety and health program finds and corrects problems before any harm is done. However many workers you employ, you have that many extra pairs of eyes to help you uncover hazards. Provide one or more systems for employees to alert you to hazards, and guarantee that employees who report hazards will be protected from harassment. Employees will need to see timely and appropriate responses to their reports. These responses are visible evidence of management's commitment to worker safety and health and your desire for meaningful employee involvement. The actual language of the Guidelines is:
So that employee insight and experience in safety and health protection may be used and employee concerns addressed, provide a reliable system for employees, without fear of reprisal, to notify management personnel about conditions that appear hazardous and to receive timely and appropriate responses; and encourage the employees to use the system.
For further information and assistance, see Chapter 9.
ACCIDENT/INCIDENT INVESTIGATION. Investigating accidents and incidents (these terms are defined in Chapter IX) presents another opportunity to find hazards and design prevention and controls. For each accident, there usually are several steps that must be taken to prevent future occurrences. The Guidelines recommend that you:
Provide for investigation of accidents and "near miss incidents, so that their causes and the means for their prevention are identified.
For further information, see Chapter 9 and the National Safety Council publication, "Accident Investigation...A New Approach."
INJURY AND ILLNESS TREND ANALYSIS. It is useful to review injuries and illnesses that have occurred over a period of time, including those illnesses that do not appear to be occupationally related. Such an analysis may reveal patterns or clusters that suggest common worksite causes or origins not apparent when the cases first were recorded. The Guidelines recommend that employers:
Analyze injury and illness trends over time, so that patterns with common causes can be identified and prevented.
HAZARD PREVENTION AND CONTROL
Once you have inventoried the hazards and potential hazards of your workplace, you can begin designing a program of prevention and control. Your program will consists of:
- Appropriate Controls
- Preventive Maintenance
- Emergency Preparation
- Medical Program
APPROPRIATE CONTROLS. In designing a program of prevention and control, the ideal choice always is prevention of employee exposure to a hazard. This means removing the hazard or preventing exposure through engineering controls. Where complete removal of the hazard is not feasible, the next best choice is complete enclosure. Where complete enclosure is not feasible, a combination of partial enclosure, safe work practices, and other administrative controls is the next best choice. To supplement these controls, you may need to use personal protective equipment (PPE).
This hierarchy of controls is subject to some variation. There may be situations, for example, where PPE is the primary means of hazard control, as in oxygen-deficient environments where respirators are essential. Because every workplace has its unique characteristics, a careful hazard analysis is a critical preliminary to decisions about controls.
Safe work practices and PPE place special responsibilities on the employees who use them. Employees should be trained (and OSHA standards require that you provide training in specified situations) to understand why they need these protections and how they can use these methods to protect themselves and others. You should stress the seriousness of these protections in every possible way, including, when necessary, the use of fair and consistent discipline.
The actual language of the Guidelines is:
So that all current and potential hazards, however detected, are eliminated or controlled in a timely manner, establish procedures for that purpose, using the following measures:
engineering techniques where feasible and appropriate;
procedures for safe work that are understood and followed by all affected parties, because of training, positive reinforcement, correction of unsafe performance, and, if necessary, enforcement through a clearly communicated disciplinary system;
other administrative controls, such as reducing the duration of exposure; and,
provision of personal protective equipment
For further information, see Chapter 8.
PREVENTIVE MAINTENANCE. A good equipment maintenance program can keep engineering control systems working as intended and can prevent ordinary non-hazardous equipment from becoming hazardous. For these reasons, the Guidelines recommend that you:
Provide for facility and equipment maintenance, so that hazardous breakdown is prevented.
For further information, see Chapter 8.
EMERGENCY PREPARATION. Planning and preparing for emergencies is an essential part of any effective safety and health program. The greater the possibility of an emergency, the more preparation should be done. All employees should know exactly what they must do in each type of emergency. With sufficient practice the responses needed at times of crisis can become practically automatic. The language of the Guidelines is:
Plan and prepare for emergencies, and conduct training and drills as needed, so that the response of all parties to emergencies will be "second nature."
MEDICAL PROGRAM. Having a medical program onsite does not necessarily mean having an onsite doctor or nurse. It does mean involving occupational health professionals in worksite analysis for hazards, in hazard prevention and control programs, in early recognition and treatment of injuries and illnesses, and in limiting the severity of illness and injury. For smaller businesses, these important tasks can be arranged by contract with occupational health professionals. In addition to health professionals, other employees at the site should be trained in first aid and CPR. The Guidelines recommend that you:
Establish a medical program that uses occupational health professionals in the analysis of hazards, early recognition and treatment of illnesses and injury, and limitation of the severity of harm; and which provides first aid and cardiopulmonary resuscitation (CPR) onsite and physician and emergency medical care nearby, so that harm will be minimized if an injury or illness does occur.
For more information, see Chapter 10.
SAFETY AND HEALTH TRAINING
For an effective program of safety and health management, it is crucial that all persons at the worksite understand their role in that program, the hazards and potential hazards that need to be prevented or controlled, and the ways to protect themselves and others. You can achieve such a program by:
- Ensuring that employees understand hazards,
- Ensuring that supervisors understand their responsibility to:
- analyze the work under their supervision of hazards,
- maintain physical protections, and
- reinforce and enforce needed protective measures; and
- Ensuring that managers understand their responsibilities.
EMPLOYEES. At a minimum, employees must know the general safety and health rules of the worksite, specific site hazards and the safe work practices needed to help control exposure, and the individual’s role in all types of emergencies. You usually can achieve this by thorough orientation, periodic safety and health training, and emergency drills. Additional specialized training may be needed to teach skills required for the job or for activities under the safety and health program. The actual language of the Guideline is:
Ensure that all employees understand the hazards to which they may be exposed and how to prevent harm to themselves and others from exposure to these hazards, so that employees accept and follow established safety and health protections.
For information about employee activities within a safety and health program, see Chapter 4. For further information about employee training, see Chapter 11 and OSHA Publication 2254 (Revised 1992), "Training Requirements in OSHA Standards and Training Guidelines."
SUPERVISORS. Supervisors should be given special training to help them in their leadership role. They should be taught to look for hidden hazards in the workplace under their supervision, to insist upon the maintenance of the physical protection in their areas, and to reinforce employee hazard training through performance feedback and, when necessary, fair, consistent enforcement. The Guidelines recommend:
So that supervisors will carry out their safety and health responsibilities effectively,
ensure that they understand those responsibilities and the reasons for
Analyzing the work under their supervision to identify unrecognized potential hazards;
Maintaining physical protections in their work areas; and
Reinforcing employee training on the nature of potential hazards in their work and on needed measures, through continual performance feedback and, if necessary, through enforcement of safe work practices.
For further information, see Chapter 11.
MANAGERS. All line managers must understand their own responsibilities for safety and health. This probably will not require special classroom training; however, you will need some form of effective communication that will raise managers’ safety and health awareness. The Guidelines recommend that employers:
Ensure that managers understand their safety and health responsibilities as described under "Management Leadership and Employee Involvement," so that managers will effectively carry out those responsibilities.
For further information, see Chapter 11.
Based on a variety of experiences, but particularly its experience with the VPP, OSHA is convinced that good management of worker safety and health protection will translate into fewer injuries and illnesses. We also believe that effective management will pay off in better employee morale, higher productivity, improved product quality, and reduced business costs. This manual can help you implement a quality safety and health management program to provide that protection. The information we present is useful whether you own or manage a small or large business. We predict that your efforts to protect your workers will be amply rewarded.