In mid-October, the U.S. Occupational Safety and Health Administration (OSHA) released an updated guidance document, Recommended Practices for Safety and Health Programs, to help employers establish comprehensive safety and health programs in their workplaces. The updated guidance is more user-friendly than the previous edition and includes two new sections.
The original Safety and Health Program Management Guidelines were issued in 1989 in an effort to encourage employers to create comprehensive injury and illness prevention programs. The guidelines are designed to be usable by any employer, in any industry, and to be particularly helpful to small- and medium-sized businesses.
As before, the guidelines are organized around core elements that OSHA considers essential to any effective health and safety program. The original five core elements—management leadership, worker participation, hazard identification and assessment, hazard prevention and control, and education and training—remain, but OSHA has added two more core elements: program evaluation and improvement and multiemployer workplace communication.
Program Evaluation and Improvement
Many OSHA standards require employers to develop and implement a written program. But, not all of those written program requirements stipulate that the program must be periodically reviewed and updated—that’s something OSHA began requiring when it found that employers were taking a “one and done” approach to written programs by putting them in place but never revisiting or updating them.
Maybe it’s true that the program you devised so carefully 25 years ago—or, for that matter, 5 years ago—is just as valid today as it was then. But chances are, it isn’t. The workforce and the workplace have probably changed; the applicable laws may have changed; and almost certainly, the technology has changed. In addition, it’s probable that there are things that were part of your original plan that didn’t work out quite as well as you would have liked: That safety committee just never got off the ground, that “action item” about replacing outdated equipment was never funded, or that initiative that was projected to reduce injuries by 40% only reduced them by 10%. In order to keep up with issues like these, it’s important to continuously track and update your health and safety program just as you would vital personnel or production issues.
OSHA recommends that employers put systems in place to evaluate and improve their safety and health programs that include:
- Establishing, reporting, and tracking goals and targets that indicate whether the program is making progress;
- Evaluating the program initially and periodically thereafter to identify shortcomings and opportunities for improvement; and
- Providing ways for workers to participate in program evaluation and improvement.
OSHA’s revised guidance is organized around “action items,” and its recommended action items for program evaluation and improvement include:
- Monitor performance and progress using both leading and lagging indicators.
- Verify that the program is implemented and operating because unless what’s on paper translates to what’s actually happening, you don’t have a working program.
- Correct program shortcomings and identify opportunities to improve, because a program that isn’t working could end up being worse than no program at all.
Tomorrow we’ll look at the other new core element in OSHA’s guidance: health and safety management in multiemployer workplaces.