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OSHA updates guidelines for safety program management

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During the final weeks of his tenure, before he returns to George Washington University as a professor of environmental and occupational health, OSHA administrator David Michaels has been tying up loose ends.

One item Michaels can check off his list: An update to the agency’s Safety and Health Program Management Guidelines – the first in nearly 30 years.

Michaels unveiled a revision of the “Recommended Practices for Safety and Health Programs” in October during the 2016 National Safety Council Congress & Expo in Anaheim, CA. The document is intended to provide employers and workers – particularly those at small and medium-sized organizations – “with a sound, flexible framework for addressing safety and health issues in diverse workplaces.”

“We really need to take occupational safety and health into the 21st century,” Michaels said during the presentation. “We think this is a great step forward.”

OSHA sought public comments and hosted a public meeting when developing the voluntary guidelines, which were initially issued in 1989. The core elements of the recommended practices are:

  • Management Leadership
  • Worker Participation
  • Hazard Identification and Assessment
  • Hazard Prevention and Control
  • Education and Training
  • Program Evaluation and Improvement
  • Communication and Coordination for Host Employers, Contractors and Staffing Agencies

“Action items” for each core element, as well as a resource for self-evaluation, are provided along with 10 recommended practices for starting a safety and health program:

  • Make safety and health the top priority at all times.
  • Lead by example.
  • Put a reporting system in place.
  • Offer training.
  • Conduct inspections.
  • Ask workers to provide ideas on controlling hazards.
  • Set up hazard controls.
  • Create instructions for emergency situations.
  • Gather worker feedback about workplace changes.
  • Strive for improvement.

“We’ve recognized most people are not going to do everything – they’re not going to have a whole program right from the beginning, but the important thing is they take the first step and do something,” Andrew Levinson, deputy director for OSHA’s Directorate of Standards and Guidance, said during a media roundtable following the presentation.

The guidelines account for changes since the document was first published, including the U.S. economy moving away from a manufacturing focus, greater technology, more diversity among workers, more sedentary work resulting in a higher risk of musculoskeletal disorders, and hazards in seemingly “safe” industries such as health care and retail.

Michaels said OSHA also has moved away from the phrase “management system” with these guidelines because many small employers assume they lack the means to have one.

“We know the large employers get this and they know how to do this and there are many other resources they have, but the small employers don’t,” he added.

The updated resource puts greater emphasis on worker participation. Through a proactive approach, managers and workers can collaborate to find and fix problems to prevent incidents, the document states.

“It’s going to save you money, it’s going to improve morale,” Michaels said. “They’re the ones who will help you. Without their buy-in, it doesn’t work.”

The guidelines are derived from OSHA programs, such as the Voluntary Protection Programs and the Safety and Health Achievement Recognition Program, and follow national and international consensus standards.

Although the resource applies to various industries, the construction industry – which has unique issues – will have its own guidelines. Michaels said “Recommended Practices for Safety and Health Programs for the Construction Industry” will be released in the near future.

“What we’re saying is, every employer – no matter the size, no matter the industry – should have a safety and health program,” he said.

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