By Tim Hahn (email) and Gary Gokey (email)
Some business owners and site superintendents live in absolute fear. The terror haunts them every day at work, and it’s never far from their minds at home. It’s not a fear of something they encounter during a typical day; nor is it an unreasonable dread of something supernatural. Still, you can see the panic in their eyes as they voice a simple question: “What if OSHA audits us?”
Complying with workplace safety rules can seem to be overwhelming, and being able to prove that you’re in compliance to a government inspector only adds to the complexity. But the simple truth is that if you’re doing everything you should be doing to protect people at your workplaces, you should be in good shape when OSHA knocks at your door. In other words, do the right things and compliance will happen.
Despite what some employers may think, workplace safety laws and standards were not enacted to frustrate businesses, but to protect their employees. If your organization is serious about making sure that your employees are safe, and you follow common-sense safety practices, you’re probably well on the way to surviving an OSHA inspection without too many bruises. That said, there are several things you can do to help compliance happen.
Training is job one
Many companies don’t perform training as often as they should, and those that do meet the standards for training often forget to document everything. When OSHA pays you a visit, one of the first things they’ll examine is how you handle training. If you can prove that you have the correct written training programs in place, that you’ve rolled out those plans so that everyone who should receive training does, and that you’re actually performing jobsite observations to verify that proper procedures are being followed, you should be in compliance.
Analyze hazards daily
A particularly effective safety strategy is to conduct a daily task hazard analysis. At the beginning of each shift, you gather your teams, review the tasks they’ll handle that day, and determine what protective equipment they’ll need. For example, if an employee will use a chainsaw, make sure he wears cut-resistant chaps in addition to gloves and face protection. This strategy works especially well when specific employee tasks may change from day to day, such as on a construction site.
Communicate clearly
Another aspect OSHA scrutinizes is your hazard communication program. They’ll want to verify that you have all of the material safety data sheets for the work that’s being done, and that workers have easy access to that information. Be sure to have the right MSDS for every aspect of your project – even if it’s some sort of coating that will be applied for just one day.
Inspect on your own
One technique that can be very effective is to perform your own mock OSHA inspections (or ask a safety consultant to do that for you). Walk around your workplace and write down every violation you notice. Determine how long each of those violations has been in place and assess an estimated fine for each. Share your findings with the staff, tell them what those violations would have cost, and warn them that you’re going to perform another inspection sometime next month to ensure that all of the violations have been addressed.
You can also use this process for positive reinforcement. When you see employees using the correct safety procedures and/or equipment, or when you notice that past deficiencies have been resolved, point them out and thank the employees. (One safety director carries small bags of M&Ms on jobsites, and tosses them to people who model correct safety behavior.) Employees who know that the right steps are going to be recognized, and who know that you actually spend time on the jobsite to monitor compliance, will be far more likely to do the right things.
Document, document, document
The most important thing you can do to make sure compliance happens is to document all of your safety-related activities. For example, if an OSHA inspector asks about your safety training, and all you can provide are vague answers, you’re opening the door for a deeper audit. But if you have clear, comprehensive documentation that spells out who was trained, what training they received, and when they received it, you’ll prove that compliance is important to you.
Good documentation will also give you a solid tool with which you can perform your own assessment of your safety program’s adequacy. If you note that employees in three areas have received extensive training, but those in a fourth have received far less, you may have identified a problem. When you address that problem, you’ll be closer to compliance — and even more important, you’ll be ensuring a safer workplace.