EHS Administration

OSHA Wants Your 2 cents on its Safety and Health Management Program Guidelines

OSHA has proposed updates to its voluntary Safety and Health Management Program (SHMP) guidelines, which were originally published in 1989. The Agency has invited public comment on the revisions—which could eventually form the basis for an OSHA standard—but only until February 15, so get your 2 cents in now.

The revisions to the guidelines were crafted on the basis of OSHA’s experiences with its Voluntary Protection Program (VPP) and Safety and Health Achievement Recognition Program (SHARP), as well as from similar industry and international initiatives such as ANSI/AIHA Z10 and OHSAS 18001.

OSHA and SHMPs

Some states require employers to implement safety and health management programs, but there is no requirement to do so at the federal level. Instead—as it often does when it cannot overcome the barriers to promulgating a new standard—federal OSHA has created a set of voluntary guidelines and is encouraging employers to adopt and implement them as a method of enhancing compliance with existing OSHA standards.

The original SHMP guidelines encourage employers to set up management programs that address:

Management Commitment and Employee Involvement. This step assigns responsibilities for all aspects of the program so that each employee knows what role he or she is to play in the protection of health and safety. In addition, workers must be given adequate authority to perform their responsibilities and be held accountable for doing so.

Worksite Analysis. This step identifies workplace hazards on an ongoing basis, through baseline surveys, ongoing inspections, accident investigations, and employee reporting systems.

Hazard Prevention and Control. This step implements controls for identified hazards.

Training. This step provides training both for employees, and for supervisors, in hazard identification and control.
The revised guidelines have been expanded to include sections specifically addressing worker participation, program evaluation and improvement, and multi-employer worksites.

What OSHA Wants to Know

OSHA’s Safety and Health Program Management Guidelines are intended for use by small and large organizations in all sectors of the economy. They focus on elements common to most effective safety and health programs: management leadership, worker participation, hazard identification and assessment, hazard prevention and control, education and training, and program evaluation and improvement. They also provide new guidance for use at multiemployer worksites.

In its request for comments, OSHA is especially interested in knowing how appropriate and useful the revised guidelines are for small- and medium-sized businesses. In addition, OSHA is asking reviewers to help them identify:

  • Case studies or other documentation that illustrates the effects (benefits, organizational impacts) of fully implementing a safety and health program similar to the program described in OSHA’s guidelines;
  • Inconsistencies between the guidelines and current consensus standards, including ASSE AIHA Z10-2012 Occupational Health and Safety Management Systems standard, or the Occupational Health and Safety Assessment Series (OHSAS) 18001 Occupational Health and Safety Management standard;
  • Workplaces where the guidelines are not appropriate or would be difficult to implement;
  • Tools and resources that could be included as appendices that would make the guidelines more helpful and useful;
  • Obstacles to the implementation of safety and health programs in small- and medium-sized workplaces;
  • Information that would persuade small- and medium-sized businesses to adopt safety and health programs; and
  • Opinions on whether a stakeholder meeting would be beneficial in further revising and finalizing the guidelines.

Tomorrow we’ll look at specific changes that OSHA has made to the guidelines.