Kevin Ian Schmidt

A Written Workplace Safety Program is a management approach for identifying, analyzing, and controlling workplace safety and health issues. This includes developing systematic policies, and practices in creating and maintaining a safe and healthy working environment. The implementation of a written safety plan is a proven and effective method for reducing the number of accidents and injuries among your employees.

Controlling injuries can save your company money in employer’s compensation costs, decrease employee time away from work, and help improve employee productivity and morale.

1. Where and How to Start

First, you will need to develop a safety policy statement. Your safety policy statement must contain short and concise statements each employee can recite. It must explain the goals and objectives of your safety and health program, reinforce the principle that safety is everyone’s responsibility and be signed by the most senior officer in the organization.

2. Commitments of the Management

Commitment’s of the management in writing the written workplace safety program include, management involvement, communicating responsibility, and resources to responsible parties and holding those parties responsible. In addition, management needs to make sure that employers are encouraged to report hazards, injuries, illness and symptoms and that there aren’t any programs or policies discouraging this report.

Check Out: Workplace Safety Meetings – 7 Ways To Increase Their Effectiveness

3. Division of Responsibilities

Your workplace safety program must explain how the responsibilities for safety and health have been assigned to managers, supervisors, employees, and any other entities (such as safety committees) in your organization. Clear assignments of responsibility will allow each employee, supervisor, and manager to know what activities and behaviors are expected. What employees, supervisors and managers are held accountable for is what normally gets accomplished in your operation. Be as specific as you can and then hold them to it. Use this as part of your performance appraisal process to evaluate employee effectiveness. Assess your current business activities, positions, and responsibilities. Make a list of all employees, showing date of hire, job description, and what experience and training each might have.

Check Out: Establishing a Safety Committee

4. Hazard Identification

Your written safety program must explain how you intend to identify, analyze, and control existing, new or potential hazards at your organization. This should include: regular inspections of your facilities, and analysis of hazard operations, carrying out workplace accident investigations, injury trend analysis, and taking action to eliminate future injuries. Be more specific and delegate who will be completing each activity, when they are to complete the activity, and how this will be evaluated for effectiveness.

Check Out: How to Conduct a Job Hazard Analysis

5. Hazard Analysis

Analyzing your hazards is an important step in reducing the potential for accidents, as it will help you use your resources more effectively when you begin to correct them. Once your hazards and potential hazards have been identified, you will need to list the methods you intend to use to analyze them. Each of these components should be evaluated independently. Once this has been done, you can combine the two components to determine the gravity of each hazard.

Check Out: PPE Hazard Assessment and Certification

6. Hazard Control

Now that the hazards have been identified and categorized, it is time to avoid them. If possible, eliminate the hazard(s) completely. If not, you must control the hazard(s) by using one or more of the following: Engineering Controls: Barricades, and ventilation systems. Administrative Controls: changing work schedules, or assignments. Generally, to manage hazards the workers will have to be trained in hazard recognition and how to reduce their exposure. Some examples of Administrative and Procedural Controls include Hazard communication programs and Lock-out/tag-out procedures. Personal Protective Equipment (PPE) such as eye protectors, hand protectors, and respirators. Personal Protective Equipment should always be used as a final option. Solutions should be sought in engineering or administrative controls first.

Check Out: What Is the Hierarchy of Control?

7. Accomplishing Hazard Identification

Hazard identification shall be accomplished using the following means: Safety/health inspections, employee safety hotline, reports of safety monitors, and review of records. Department supervisors will conduct inspections in their departments quarterly on the first Friday during the months of February, May, August, and November. Hazards reported through the employee safety hotline will be sent to the corresponding department supervisors. The hotline information will not have employees’ names. The goal is to learn what the hazards are and correcting them. No one will take any unfavorable action against anyone for identifying a hazard. The reports of the safety monitors will be sent to the safety committee and the plant manager. The safety manager will evaluate the hazard bulletins and provide them to the department supervisors to be addressed at the next department meeting.

Check Out: How to Develop an Internal Safety Audit Schedule

8: Role of the Safety Managers

The safety manager will coordinate the hazard analysis effort. The safety manager will review accident investigation reports to identify the need to improve training, evaluate if corrective action has been addressed, and determine that action has been taken to reduce injuries. Any problems identified may indicate a need to address the system, processes, and controls. The safety manager will communicate results of the area and personal sampling to the employees and supervisors. The supervisors must correct problems resulting in levels discovered that are beyond acceptable limits. Any sort of necessary action out of the supervisor’s control will be directed to the plant manager and safety committee. Department supervisors will conduct a job hazard analysis at least annually for each job classification in their departments and ensure they are updated. This includes a hazard assessment for personal protective equipment (PPE). The safety manager and safety committee will evaluate accident trends from the policyholder statements and OSHA Injury and Illness log while ensuring the appropriate confidentiality. They will notify and work with the department managers to evaluate solutions and implement procedures or controls to reduce future injuries.

9. Accomplishing Control

After a hazard has been analyzed, it must be given priority based on its overall gravity. Hazards will then be controlled as any hazard that can be eliminated. All other hazards will be controlled by using engineering or administrative controls or a combination of these as appropriate. The supervisors must correct hazards within their control and ensure the remaining hazards are passed to the plant manager and safety committee for action. The safety committee and plant manager will evaluate and implement controls for the hazards. Administrative and work practice controls for hazards will be either designated as a separate program or part of our procedures.

10. Safety Procedures

The safety manager will monitor the progress of all abatement procedures and ensure that all affected employees are apprised of the status. The safety manager will coordinate safety communication to vendors and subcontractors working within the plant. The safety manager will provide the company president with the status of implemented controls, needed controls based on hazards, injuries and regulations.

Once the workplace safety program is been prepared after thorough analysis, training programs need to be established. Items to train your employees on include your safety program, their rights; compulsory training based on the OSHA regulations. Your written safety program must include an explanation of your training policy and procedures. This should include who will conduct the training, how often training will be completed, a list of the training required for your activities, how the training lesson plan will be maintained, and how the training records will be maintained. Providing training to your staff and employees is a crucial part of having an effective safety and health program.

In fact it may be the most crucial element. After all, a well-trained employee can be a much safer and more productive employee.

Work Environments While Traveling

Work in the interest of the employer. Injuries and illnesses that occur while an employee is on travel status are work-related if, at the time of the injury or illness, the employee was engaged in work activities “in the interest of the employer.” Examples of such activities include:

• Travel to and from customer contacts, conducting job tasks, training, work-related meetings, and entertaining or being entertained to transact, discuss, or promote business. Work-related entertainment includes only entertainment activities being engaged in at the direction of the employer.
• Similarly, if an employee is injured in an automobile accident while running errands for the company or traveling to make a speech on behalf of the company, the employee is present at the scene as a condition of employment, and any resulting injury would be work-related.

Home Away From Home. When a traveling employee checks into a hotel, motel, or into another temporary residence, for one or more days, he or she establishes a “home away from home.” After he or she checks in, evaluate the employee’s activities for their work-relatedness in the same manner as you evaluate the activities of a non-traveling employee. For example:

• When the employee checks into the temporary residence, he or she is considered to have left the work environment. When the employee begins work each day, he or she re-enters the work environment.
• If the employee has established a “home away from home” and is reporting to a fixed worksite each day, you also do not consider injuries or illnesses work-related if they occur while the employee is commuting between the temporary residence and the job location.

Taking a Detour. Injuries or illnesses are not considered work-related if they occur while the employee takes a detour for personal reasons from a reasonably direct route of travel. For example, the employee took a side trip for personal reasons.

OSHA has decided not to limit the recording of occupational injuries and illnesses to those cases that are preventable, fall within the employer’s control, or are covered by the employer’s safety and health program.

The issue is not whether the conditions could have, or should have, been prevented or whether they were controllable, but simply whether they are occupational, i.e., are related to work. This is true regardless of whether the employee is injured while on travel or while present at the employer’s workplace.

• An employee who is injured in an automobile accident or killed in an airline crash while traveling for the company has clearly experienced a work-related injury that is rightfully included in the OSHA injury and illness records and the Nation’s occupational injury and illness statistics.

Check Out: Conduct Your Own Mock OSHA Inspection

OSHA believes that employees who are engaged in management, sales, customer service and similar jobs must often entertain clients, and that doing so is a business activity that requires the employee to work at the direction of the employer while conducting such tasks. If the employee is injured or becomes ill while engaged in such work, the injury or illness is work-related and should be recorded if it meets one or more of the other criteria (death, medical treatment, etc.).

• Gastroenteritis, for example, is one type of injury or illness that may occur in this situation, but employees are also injured in accidents while transporting clients to business-related events at the direction of the employer or by other events or exposures arising in the work environment.

On the other hand, not all injuries and illnesses sustained in the course of business-related entertainment are reportable. To be recordable, the entertainment activity must be one that the employee engages in at the direction of the employer. Business-related entertainment activities that are undertaken voluntarily by an employee in the exercise of his or her discretion are not covered by the rule.

• For example, if an employee attending a professional conference at the direction of the employer goes out for an evening of entertainment with friends, some of whom happen to be clients or customers, any injury or illness resulting from the entertainment activities would not be recordable. In this case, the employee was socializing after work, not entertaining at the direction of the employer.
• Similarly, the fact that an employee joins a private club or organization, perhaps to “network” or make business contacts, does not make any injury that occurs there work-related.

Note that the recordkeeping regulation does not apply to travel outside the United States because the OSH Act applies only to the confines of the United States (29 U.S.C. Section 652(4)) and not to foreign operations. Therefore, the OSHA recordkeeping regulation does not apply to non-U.S. operations, and injuries or illnesses that may occur to a worker traveling outside the United States, so those incidents are therefore not rising to the level of OSHA recordability.

Working at Home. Injuries and illnesses occurring while the employee is working for pay or compensation at home should be treated like injuries and illnesses sustained by employees while traveling on business. The relevant question is whether or not the injury or illness is work-related, not whether there is some element of employer control. The mere recording of these injuries and illnesses as work-related cases does not place the employer in the role of ensuring the safety of the home environment.

OSHA has issued a compliance directive (CPL 2-0.125) that clarifies that OSHA will not conduct inspections of home offices and does not hold employers liable for employees’ home offices. The compliance directive also notes that employers required by the recordkeeping rule to keep records will continue to be responsible for keeping such records, regardless of whether the injuries occur in the factory, in a home office, or elsewhere, as long as they are work-related, and meet the recordability criteria.

Work-Relatedness While Working Remote

When an employee is working on company business in his or her home and reports an injury or illness to their employer, and the employee’s work activities caused or contributed to the injury or illness, or significantly aggravated a preexisting injury, the case is considered work-related and must be further evaluated to determine whether it meets the recording criteria. If the injury or illness is related to non-work activities or to the general home environment, the case is not considered work-related. For example:

• Work-related. If an employee drops a box of work documents and injures his or her foot, the case is considered work-related.
• Work-related. If an employee’s fingernail is punctured by a needle from a sewing machine used to perform garment work at home, becomes infected and requires medical treatment, the injury is considered work-related.
• Non-work-related. If an employee is injured because he or she trips on the family dog while rushing to answer a work phone call, the case is not considered work-related.
• Non-work-related. If an employee working at home is electrocuted because of faulty home wiring, the injury is not considered work-related.

Reporting Unclear Injuries and Incidents

If an employee reports a condition but cannot say whether the symptoms first arose during work or during activities off work, the employer must evaluate the employee’s work duties and environment to decide if one or more events or exposures in the work environment caused or contributed to the condition or significantly aggravated a preexisting condition. Below are examples of work-related and non-work-related incidents:

• Work-related. If the employee is diagnosed with Lyme disease, the employer would determine the case to be work-related if the employee was a groundskeeper with regular exposure to outdoor conditions likely to result in contact with deer ticks.
• Work-related. If an employee trips while walking across a level factory floor, the resulting injury is considered work-related under the geographic presumption because the precipitating event — the tripping accident — occurred in the workplace. The case is work-related even if the employer cannot determine why the employee tripped, or whether any particular workplace hazard caused the accident to occur.
• Non-work-related. If an employee has a staph infection, the employer would consider the case not work-related if the infection is an isolated incident – no other employees with whom the newly infected employee had contact at work had been out with a staph infection.
• Non-work-related. If an employee reports a swollen joint, but cannot say whether it resulted from an event that occurred at work or at home, the employer might determine that the case is not work-related because the employee’s work duties were unlikely to have caused, contributed to, or significantly aggravated such an injury.

View the OSHA Recordability Flowchart below