Many workers now perform their tasks at worksites other than those owned or operated by their employers. In these situations the employer remains primarily responsible for ensuring that employees have safe and healthful workplaces.
In the minerals industry, we work with people who have a range of different attitudes toward safety and how much risk they’ll take on the jobsite.
In a BLR webinar entitled "Remote Employees: Practical Dos and Don’ts for Protecting Off-Site Workers (and Decreasing Your Liability)," Adele L Abrams, Esq., CMSP, of the Law Office of Adele L. Abrams PC, offered some guidance for employers dealing with safety issues for off-site employment.
Employers cannot evade responsibilities by having employees perform work at third party or remote location, says Abrams. Rather, they must:
- Provide adequate supervision, to the extent possible.
- Exercise due diligence and take all measures reasonable in the circumstances for the protection of workers.
- Inspect each remote worksite in advance, if possible, and advise workers of potential hazards and methods of risk mitigation, appropriate PPE, etc.
- Be aware of specific requirements for certain tasks, such as diving or confined space entry, that may have requirements for the number of people required to be present and may preclude assigning employees to work alone at remote locations.
- Abide by regulations that deal specifically with working alone (e.g., communication requirements).
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Improving Off-Site Safety Programs
Abrams urges employers to improve their off-site safety and health programs by:
- Appointing well-qualified safety and health personnel who have the authority to make site safety and health decisions.
- Tailoring and updating the off-site safety and health plan to reflect remote site conditions and work practices throughout the life of a project, including coordination with other employers who have a presence at the remote worksite.
- Quantifying worker exposure levels using appropriate sampling methods.
- Selecting PPE based on accurate, site-specific job hazard analyses.
- Evaluating safety and health procedures on an ongoing basis and documenting deficiencies and corrective actions.
- Planning and practicing emergency response procedures thoroughly so that on-site personnel and local responders know how to respond to emergencies.
Safety Programs for Off-Site Work Locations
OSHA provides little guidance about off-site safety programs on its website. Some unions, such as the American Postal Workers Union and the AFL-CIO, do address off-site safety programs.
A company’s responsibilities increase when the company has supervisors at off-site locations who oversee daily conditions and employee actions. Written programs can help delineate responsibilities and issues for safety programs at off-site locations.
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To address off-site operations, Attorney Abrams says safety programs should include the following:
Policy. The policy should affirm that the goal is prevention of injuries and illnesses at all locations where employees are present, including off-site operations.
Scope. The scope of the policy/program should apply to all employees regardless of location of work assignment. It may address worksites outside the United States in a separate document, as warranted. The scope may also address safety for third parties such as consumers and contractors.
Oversight. The program should address which internal departments and staff have oversight responsibilities for safety at off-site locations.
The safety and health department should be notified of the deployment of personnel to off-site locations as early as possible during the proposal phase of projects so the unique needs of the off-site location can be identified and addressed. Safety representatives may need to visit off-site operations (other than home offices) to:
- Observe local conditions.
- Inspect facilities prior to operations.
- Evaluate operating procedures and determine PPE and other needs.
- Ensure that contractual terms concerning safety are being satisfied.
- Coordinate training, supervision, PPE provision, reporting etc. with host employer.
Tomorrow, We’ll address safety precautions for solo workers.
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