EHS Management

What’s New in OSHA’s Draft Safety and Health Program Management Guidelines?

In 1989, OSHA published a guidance document to aid employers in creating an effective umbrella program encompassing all of its safety and health management activities. OSHA issued a draft update of these guidelines in November 2015, for public comment. The comment period closed in February, and OSHA is poised to issue its updated guidelines.

Keep reading to find out what’s new in OSHA’s Safety and Health Program Management (SHPM) guidelines.

Changes to the Guidelines

Here’s what OSHA highlights in its updated guidelines:

A proactive approach to finding and fixing hazards. Many safety and health programs are reactive, OSHA says, using reports of injuries and illnesses to identify problems that are then addressed after the fact, but OSHA wants employers to develop a preventive health and safety mind set. This is reflected largely in a change in terminology but also in some of OSHA’s specific recommendations.

In OSHA’s 1989 SHPM guidelines, “Worksite Analysis” was a major program element, but OSHA has relabeled this section “Hazard Identification and Assessment.” The emphasis is no longer on examining the worksite but on identifying hazards – an ongoing process that seeks to identify hazards before a worker becomes ill or is injured or killed. OSHA recommends that employers:

  • Collect information about the workplace that can be used to identify hazards, such as the types of equipment and chemicals that are in use.
  • Inspect the workplace periodically for the purpose of identifying hazards.
  • Investigate not just accidents but also near misses and close calls to identify underlying hazards.
  • Think in advance about the sorts of hazards workers might face in emergency or nonroutine situations.

Improved safety and health in all types of workplaces. OSHA admits that these guidelines may not be a good fit for construction industry employers, and it plans to issue a separate set of guidelines for them. However, OSHA states that the revised guidelines are specifically designed and intended to be useful to employers in a range of industries, including manufacturing, hospitals and healthcare facilities, offices, and service industries. The previous guidelines did not explicitly count in the development process for the requirements of a broad range of industries. Employers who had trouble applying the 1989 guidelines to their workplaces may find the revised guidelines easier to use.

Help for small- and medium-sized businesses to effectively protect their workers. Small businesses can’t always make the kinds of investments that large businesses can— however, they don’t always need to. OSHA has tried to design guidelines that can be implemented in any size business; in part, they have done so by emphasizing that communication in small businesses can be effectively done orally, and it need not always be done in formal written documents. In addition, OSHA alleges that the source material on which the guidelines are modeled has been successfully tested by small employers. The guidelines draw heavily from OSHA’s Safety and Health Achievement Recognition Program (SHARP) guidelines. According to OSHA, when its SHARP guidelines were implemented by small employers in Ohio, they saw a dramatic decrease in workers’ compensation claims. OSHA also recommends that small- and medium-sized employers take advantage of its free on-site consultation program to identify hazards and implement the program.

Program evaluation and improvement. This is a new section, emphasizing that OSHA does not see a safety and health management program as a “fix it and forget it” recipe. Rather, OSHA recommends that employers periodically evaluate control measures for effectiveness, establish processes to monitor program performance, verify program implementation, identify program deficiencies and opportunities for improvement, and take actions necessary to improve the program and overall safety and health performance.

Better communication and coordination on multiemployer worksites. This is a new section, reflecting OSHA’s recent emphasis on multiemployer worksites and contract and temporary employees. OSHA has made this an area of heightened enforcement because it believes that they are a frequent, ineffectively addressed source of worker injuries, illnesses, and deaths. OSHA recommends that:

  • Host employers and all contract employers coordinate on work planning and scheduling to identify and resolve any conflicts that could impact safety or health.
  • Workers from both the host and contract employer are informed about the hazards present at the worksite and the hazards that the work of the contract employer may create on-site.

Tomorrow we’ll look at the most controversial change to the guidelines: the emphasis on increased worker involvement and its potential, chilling effect on employee incentive programs.