To Write or Not to Write - That is the Question
Whether your business is undergoing a self-imposed health and safety audit, a voluntary audit from an accredited organization, or a not-so-voluntary inspection through a regulatory agency, one of the first items likely to be requested by the auditor is a copy of your written programs. These written programs are valuable as they outline performance expectations and provide well defined procedures for maintaining compliance.
And yet, in spite of their enormous value, most of the program areas associated with OSHA standards do not require the business to establish formal written programs. For example, the following OSHA standards:
- 29 CFR 1910.29 Fall protection systems and falling object protection - criteria and practices.
- 29 CFR 1910.67 Vehicle-mounted elevating and rotating work platforms.
- 29 CFR 1910.178 Powered industrial trucks
- Subpart O - Machinery and Machine Guarding
- Subpart Q - Welding, Cutting and Brazing
These programs often include high-risk activities that can lead to serious incidents when not performed properly. But OSHA’s regulations only set the performance expectations of the business and not the methods for achieving compliance.
Despite the extra work and time involved, it is in every business’s best interest to maintain a written program, even if the regulation does not require it. It really is just common sense. Businesses already establish health and safety programs (a set of related measures or activities with a particular long-term aim) to prevent workplace injuries, ensure compliance with laws and regulations, reduce costs, and improve employee morale. Documenting these measures and activities in a written format is one of the most effective ways to communicate to your employees, at all levels, the expectations of leadership as it pertains to safety and health. Well written safety and health programs provide the business with a roadmap to achieving success.
Written health and safety programs also provide a consistent reference for how the business is going to remain compliant and help to avoid any disputes that site personnel may have regarding their responsibilities. Written programs provide program sustainability and simplify personnel turnover as new hires are onboarded. A good way to gage your written program is whether new personnel can seamlessly take ownership of the program and understand all their responsibilities and methods for maintaining compliance.
What Does a Well Written Program Look Like?
Hopefully by now you’ve come to realize the value of a written program and are wondering what a good written program looks like. Keep these pointers in mind:
- Well written programs are specific to the site and relevant to the operations. Take, for example, a site on which employees are required to operate electric forklifts. You would expect to see information related to the safe operation of an electric forklift. What you would not expect to see is safe handling procedures for propane cylinders used with propane forklifts or information related to operating forklifts in potentially explosive atmospheres, assuming, of course, the site does not have any. Providing documentation of operations that are not pertinent to the site may lead to confusion among site personnel and the assumption that the site has risks that are not present.
- Written programs should be short and to the point, providing instructions that are relevant and easily understood by those who have responsibilities under the program. For instance, if the respiratory protection standard maintains the employer shall provide each respirator user with a respirator that is clean, sanitary, and in good working order (29 CFR 1910.134(h)(1)), your program should restate the requirement and also provide the methods that you will use to achieve compliance with this standard. These methods should include the following:
- Who –Who performs the cleaning of the respirators, who maintains resources for performing cleaning activities, etc.
- What – This may include the resources provided for cleaning, such as sinks, cleaning agents, etc.
- Where – This may include the location of approved sinks for cleaning operations and locations where materials for cleaning may be replenished.
- When – Should indicate how often respirators are to be cleaned. This information should be specific to the operation. Some respirators may require cleaning more frequently than others.
- How – In this case, the program may refer to the training that operators are given or to an appendix that provides detailed work instructions or references.
- Written programs should be practical and inclusive. When developing the program, be sure to get the input of the employees required to carry out the requirements of the program and the methods that are defined. Auditors often find that the expectations and methods written in the program do not always match the methods employed on the site, and that undermines the purpose of the written program.
- Programs should be reviewed regularly and updated as needed. A health and safety program is a living document that should grow with the business. It is not something that, once written, is buried in a drawer or collects dust on a shelf. Employees should continually be familiar with its contents and with any updates that may take place.
Developing Written Safety and Health Programs
The methods that businesses use to identify and assign health and safety responsibilities varies. There is no one-size-fits-all method that works best for everyone. Some businesses find that their operating model best fits assigning responsibilities to dedicated safety and health personnel. Others may decide to diversify safety and health responsibilities to those with the most direct responsibility for implementation of the program.
But despite the customizability of written health and safety programs, they should all have the same foundational elements. OSHA recommends the following practices for health and safety programs:
- Management leadership
- Worker participation
- Hazard identification and assessment
- Hazard prevention and control
- Education and training
- Program evaluation and improvement
Like OSHA, ISO 45001 establishes similar foundational elements, but provides more detailed guidance for establishing these programs. The most recent publication of ISO 45001-2018 still requires organizations to implement and document health and safety procedures in a structured way. However, the methods for implementation of the procedures are not specified in the standard. This update provides businesses the means to establish programs that best meet the needs of their business, while simultaneously allowing the organizational structures to be taken into consideration. This is important as the extent of the documentation related to individual written programs can differ from one business to another due to the size of organization and its type of activities, processes, products, and services, as well as the complexity of the processes and the competency of the individuals with responsibilities under the programs.
Regardless of which regulatory entity you follow to establish your written program, the investment of time and effort to document health and safety programs is time well spent. Documenting responsibilities and methods for compliance will ensure that your program is sustainable and consistent, which should help ensure workplace safety and regulatory compliance.