Speaking of Safety Programs and Policies…

Most companies like yours have a written safety program that spells out the company’s safety policies, procedures and responsibilities. However there is a dilemma with written safety programs, which could cause a lot of problems for a company, especially if that company is involved in an OSHA hearing or some form of litigation related to safety.

There is more to having a written safety program, which includes policies, procedures and rules. No matter how well written your program is, if managers don’t know what it says or they don’t implement the established policies and procedures, your company is vulnerable to potential accidents, catastrophic events and liability.
When an individual is promoted to a management level job, be it foreman, superintendent, project manager, vice president or even CEO, companies must ensure the individuals have the tools and information they need to assume their responsibilities. If there is no plan to ensure they have what they need and know what they are expected to do, they are often left in a position where they are bound to make mistakes. These mistakes often result in inefficiency, lost profits, and from the safety standpoint, accidents and work-related injuries or illnesses.

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With this in mind, I would like to focus on management safety responsibilities. A well prepared safety program should spell out management responsibilities. Refer to your safety manual to see if it has a section that assigns management safety responsibilities. If the safety manual does not have a section for the assignment of responsibility, it should.

For example, it may say something like this:

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Project managers, superintendents and foremen, hereinto referred to as supervisors, are the leaders and are in charge of the continuous supervision of employees. Therefore, they play a key role in the safety and health program. They must make safety and health a part of their regular supervisory activities. Since employees look to their supervisors for leadership, therefore supervisors must set a good example by adhering to safety rules and by following safe work procedures.

All supervisors must be knowledgeable about the safety regulations that apply to the work they supervise. Supervisors are also responsible for seeing that safety and health rules, and safe work procedures relating to their operation, are followed. When violations are observed, supervisors must take action to eliminate or control the hazard, or remove employees from the hazard or work area. When employees violate company safe work rules or safe work procedures, the disciplinary action procedure must be implemented.

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Let me paraphrase the rest of this policy by saying the policy goes on to say that supervisors must ensure workers are aware of the company safety rules and safe way to perform their jobs through training and weekly tool-box talks. It says supervisors must make regular safety inspections of work areas, materials and equipment using the inspection form. It also requires supervisors to investigate accidents to determine the cause. Last but not least, it goes on to say supervisors will be held accountable for compliance with safety activities, especially training and hazard control.

This is just a sample of what a safety program might say, but have all the supervisors actually read the safety program and do they clearly understand their responsibility for implementing it?

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Although many managers know they have some responsibility for safety, many have never really reviewed the safety program. In the insurance industry we used to call it a paper program, which is a written safety program, often copied from a boiler plate document with the blanks filled in. These programs often sat on the shelf collecting dust and are seldom, if ever, referred to.

It’s okay to use a boiler plate as a guide when creating a safety program. However, it is important to remember that your company can be held accountable for everything they put in writing, which is why I always tell companies to review their safety programs on an annual basis with their management team. The purpose of the annual review is to make sure what has been put in writing is actually done. Any sections of the manual that are not used or implemented as described in the manual should be revised or removed.

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Never be afraid to revise or remove worthless procedures, policies or rules if they are not implemented or needed anymore. There are too many safety programs in the industry today which are 2 to 3 in. thick that are loaded with worthless and/or complicated policies and procedures. If your safety program is a 3-in. binder, ask yourself, who is going to read it? Seriously think about how to simplify and/or streamline it, so people will actually read it and refer to it when needed.

We often talk about the importance of knowledge and training as the key to preventing accidents; however, we often forget about educating managers and supervisors. We assume they know what they must do. After all, they are managers. Every supervisor should always have an up-to-date copy of the safety program available. The safety program should be required reading for every supervisor.

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Managers at all levels should have safety training relative to the type of work their employees perform. A good place to start might be requiring all project managers and superintendents to complete a 30-hour OSHA Construction Outreach Program. Foremen, at a minimum, should be required to complete an OSHA 10-hour Construction Outreach Program. How can a company expect its supervisors to ensure OSHA compliance if they don’t know the applicable regulations?

Senior managers, with the help of the safety manager, should hold meetings with all levels of the management team to discuss safety issues, problems, policies and procedures. Managers at all levels, starting at the very top, must understand they have a responsibility for safety whether they want it or not. It cannot be delegated and forgotten.

Find the time to ask your managers and supervisor if they have a copy of the safety program. Determine if they have ever actually read the safety program. Find out what they know about the company’s safety program, policies and procedures. See if they know and understand their safety responsibilities. Find out what they know about applicable OSHA regulations and what safety training they have had. In addition, find out if they make regular routine safety inspections, provide safety training and tool-box talks (Note: tool-box talks are not a substitute for proper safety training), enforce rules and ensure safety procedures are followed. In a sense, give them a test to see what they really know and understand about their safety responsibilities. I think many readers of this article will be in for a rude awakening when they realize how little managers and supervisors really know about the company safety program, their safety responsibilities and applicable OSHA regulations.

If the company ever has an OSHA inspection, the compliance officer will ask the supervisor(s) at the jobsite what he or she knows about the company safety program. What they don’t know or do could result in a citation.

If the company is ever involved in a legal proceeding involving an accident, the managers on the job, as well as the superintendent and/or project manager, will probably be deposed and have to give testimony under oath about safety on the jobsite. And you can rest assure that the attorney for the plaintiff will ask pointed questions to make the supervisor look as if he or she did nothing about safety because they did not even know their safety responsibilities and the safety regulations and/or procedures related to the type of work being performed. In a juror’s eyes, it does not look good for the company, and it is embarrassing for the supervisor.

Construction employers do not want workers to be injured or accidents to happen at their jobsites. Therefore, they create safety programs to establish safety policies, procedures and rules for supervisors and employees to follow. Unless supervisors are acutely aware of their responsibilities and the content of the safety program, implementation of the program will be strictly arbitrary and many of the policies, procedures and rules will be overlooked and never implemented.

To prevent a company’s safety program from being a paper program, include discussions about safety in all management meetings. Make safety an agenda item. Senior managers and safety managers should facilitate conversations with managers and supervisors at all levels about their responsibilities and the safety program, policies and procedures. Make safety important and a top priority for managers and supervisors as it should be by ensuring they know their safety responsibilities.

George Kennedy is NUCA Vice President of Safety.