Osha published guidelines for general safety and health program management

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We use cookies to provide you with a better experience. By continuing to browse the site you are agreeing to our use of cookies in accordance with our Privacy Policy. Home » OSHA updates guidelines for safety program management. One Comment. Lead by example. During the public meeting, OSHA was informed that the VPP Participants' Association might be able to obtain information concerning costs and benefits of effective safety and health management through its membership Tr.

As a means of educating employers, one commentator suggested videotaping model safety and health programs to help small businesses Exh. Another commentor advised a major outreach effort using all types of media to reach employer Exh. Suggested incentives for effective management included tax breaks Exh. One commentor suggesting the tax breaks acknowledged that they might be difficult to administer fairly Exh.

Another commentor proposed the use of the guidelines by compliance officers to determine whether or not to do a partial or comprehensive inspection Exh. Several however, also expressed a preference that the guidance from OSHA take the from of a mandatory standard rather than of voluntary guidelines Exhs. Almost all the commentors endorsed the concept that effective safety and health management is the decisive factor in ensuring worker safety and health e.

Three-fourths of the respondents specifically endorsed the issuance of guidelines. A few respondents objected to the proposal because of expected cost, anticipated impact on diversity and innovation, or the possibility of confusion resulting from the issuance of voluntary guidelines by a regulatory agency e. Most respondents indicated that the guidelines are generally applicable regardless of industry type, size, or nature of activity e. Several commentors recommended greater detail and specificity regarding duties, responsibilities, and program guidance e.

Although some proposed reorganization of the guidelines e. Many respondents strongly maintained that the guidelines should specify that safety and health management goals and operational activities should be set forth in writing, regardless of how small the business may be Exhs. Several commentors, including both organized labor respondents, maintained that compliance with the guidelines ought to be mandatory Exhs. The majority maintained that they should not.

Several commentors provided safety and health program manuals and materials and suggested that the guidelines include appendices for industry groups or examples of adequate programs or "question and answer" examples similar to those in the "Recordkeeping Guidelines for Occupational Injuries and Illnesses" developed by the bureau of Labor Statistics Exhs. Although commentors almost unanimously supported the concept of safety and health program management they raised several genre issues and proposed various changes to the language.

The general issues were: 1 Whether OSHA publication of guidelines would be useful; 2 whether a different organization of the management program elements would promote their use; 3 whether the guidelines should be mandated in the form of a rule; 4 whether a task group should be formed to determine the content of the guidelines; and 5 whether various aspects of a safety and health management program should be in writing.

A few respondents stated that safety and health program guidelines would be of no value or even counter-productive. Most of the respondents expressed the belief that the guidelines describe policies, procedures, and practices which are essential to effective safety and health protection and that they are sufficiently performance-oriented that they can be met by a variety of methods. OSHA believes that the criteria described are not unreasonably prescriptive and that they are unlikely to conflict with effective programs already in place.

They are not being promulgated as enforceable rules by are being issued as guidelines to assist employers in their efforts to maintain safe and healthful work and working conditions. In addition, OSHA has observed and most commentors agree, that a significant number of worksited, particularly medium and small businesses, often lack the professional resources to develop adequated safety and health management practices and programs on their own.

IN many larger worksited, some program elements are heavily emphasized while other important aspects are neglected. After careful consideration of the record and in light of the above, OSHA concludes that safety and health management guidelines will not be unnecessarily burdensome and will assist employers in their efforts to provide safe and healthful employment.

Some commentors suggested different methods of organizing the elements of the guidelines or presented safety and health manuals in use at their operations which were organized differently. One respondent stated that since some of the most useful material in the notice requesting comment 53 FR was in the discussion of the guidelines, the suggested language should be expanded to include that material in the final guidelines.

A suggested revision of the guidelines was attached to the comment Exh. OSHA recognizes that effective programs can be organized and presented in a variety of ways and that significantly different terminologies and approaches are used by safety and health professionals and loss control managers. While these differences often appear to be great initially, upon examination by the Agency they are frequently found to address substantially the same components and objectives.

Since the responses to the request indicated that the program elements were generally understood, the basic organization of the elements as presented in the request for comments has been retained in the final version. OSHA has, however, incorporated some of the background and explanatory materials into the guidelines to assist the employer's comprehension of the objective of each action recommended by the guidelines.

The commentary incorporates and expands on much of the explanatory material from the notice requesting comment. Another commentor questioned whether management commitment is appropriately described as a program element Exh. OSHA agrees with the observation that management commitment is not a program element in the same sense that worksite analysis, hazard prevention and control, and training are. However, the eight actions described under the title "Management Commitment" are specific program activities which directly indicate management commitment.

At the same time, comments received on the he nature and importance of employee involvement in an effective safety and health program Exhs.

Several commentors stated that the guidelines should be mandated and enforced as a rule. After considering written comments and oral presentations made at the information-gathering meeting. OSHA has decided to issue voluntary safety and health program guidelines rather than a mandatory standard.

A period of experience with published program guidelines will undoubtedly produce refinements in methods and practices, as well as provide evidence to indicate whether further action by the Agency is required. Publication of guidelines does not prevent the Agency from undertaking regulatory action, if found to be needed at some future date.

Several commentators favored the formation of a task group representing the affected constituencies and subject matter specialists to refine and further elaborate the guidelines [Exhs. It was also suggested that a bibliography of literature on safety and health management be developed and attached to he guidelines [Exhs.

OSHA welcomes all information and voluntary efforts designed to supplement these guidelines for use in special industry groups, special risk operations, small businesses, and nay other applications. The Agency recognized the value of these supplementary actions but will not delay publication of the guidelines while awaiting their completion. After publication, OSHA will consider how best to utilize the offers of assistance in compiling supplementary materials.

A number of respondents strongly urged that safety and health programs be supported by written guidance in all cases. Understandings and practices are too easily confused [considering] cultural differences, personnel retirements, transfers, etc.

This point is reinforced by OSHA's experience that almost all of the worksites observed to have excellent safety and health programs have written guidance covering such issues as policies, practices, procedures, emergency plans, posted signs, and performance objectives.

It is not obvious at what level of complexity, or at what size of operation, written guidance becomes necessary, nor which particular processes within various operations require it. For these reasons, OSHA has retained in the final guidelines the language providing to flexibility in the use of written guidance but has added information on the benefits of written guidance. Issues dealing with the substance of the guidelines were: 1 whether employees should be involved in the structure and operation of the program and in decisions which affect their safety and health, b 1 ii ; 2 whether the system to encourage employees to report conditions that appear hazardous should include the concept of protection from reprisal, b 1 ii ; 3 whether the term "competent persons" should be used, b 1 i ; 4 whether "a clearly communicated disciplinary system" should be specified, b 3 i ; 5 whether employers can be expected to ensure understanding of rules, responsibilities, and procedures by members of their organizations, b 4 ; 6 coordination with other OSHA instructions concerning safety and health management; 7 providing guidance on recordkeeping; and 8 miscellaneous clarifications.

Some respondents felt that OSHA's language on employee involvement, b 1 ii , was too weak. Other commentors agreed with the OSHA concept of employee involvement in decision-making and suggested added specifications such as advising employee involvement in all of the suggested possible areas of employee participation Exh. Most testimony at the public meeting which addressed this point also supported OSHA's choice of language [Exh.

OSHA has decided to retain the proposed language with slight revision and with the addition of a clause that explains its intent. OSHA agrees that responsibility for decision-making lies with the employer. It has found, however, that employee involvement in decisions affecting their safety and health results in better management decisions and more effective protection.

OSHA has therefore added explanatory language in its Commentary on the guidelines to make clear its intention to advise that employee not make decisions but that they be included in the process on decision-making on matters which affect their health and safety. Some commentors felt that OSHA provisions for employee reports of hazards b 2 ii , were inadequate.

OSHA;s own experience, reflected in the VPP requirements, indicates a clear need for a system under which employee reports of safety and health concerns are encouraged, protected from reprisal, and given an appropriate response in a reliable and timely fashion. OSHA agrees that a similar provision should be a part of these guidelines as well. Accordingly, a separate provision to that effect has been included in the section dealing with worksite analysis.

Use of the Term "Competent Person" Several respondents questioned the use of the term "competent persons," b 2 i , to describe the need for expertise and experience in the conduct of periodic worksite analysis Exh. No one disputed whether persons conducting the analysis should be competent but questioned whether the term "competent" might be misunderstood in view of the many different risk situations and conditions possible in various workplaces and given that the term has specific meaning in maritime and construction standards.

Since the performance objective of a worksite analysis is defined in the phrase "so that all hazards and potential hazards are identified," OSHA agrees that it is not necessary to state the need for competence by persons who perform the work. That need is implicit. The emphasis on competence was included initially because many processes, equipment, and substances in use at worksites may pose hazards beyond the recognition of the employer and employees at the site.

This point is made clear in paragraph c 2 ii and the term "competent" has been removed. A discussion of the relative competence needed for the various approaches to worksite analysis is, however, included in the Commentary. The proposed guidelines called for "a clearly communicated disciplinary system" as one of the sub-elements for hazard prevention and control, b 3 i.

One respondent suggested that such a system is more logically a part of training. Others questioned whether it should be contained in the guidelines at all. For example. On the other hand, some commentors felt that OSHA had not emphasized discipline enough. In the revised final version of the guidelines.

OSHA refers to enforcement of safe work procedures through a clearly communicated disciplinary system where necessary to the control or prevention of hazards. See paragraph c 3 i. OSHA views this reference to enforcement through a disciplinary procedure as an indispensable piece of a whole approach to safety and health protection. Based on OSHA's experience and in light of the record, the Agency concludes that there is little possibility of effective safety and health protection without carefully designed rules for safe and healthful practices that cove all personnel, from the site manager to the hourly employees.

Since those most involved with activity which could expose them to hazards are often the hourly employees, it makes good sense to involve them in the establishment of safe work practices and safe work rules as was discussed at the public meeting Tr. Once these work practices are established and those who are expected to follow them understand why it is important to follow them, it is OSHA's experience that there is little need to utilize a corrective disciplinary system to ensure that they are followed.

When safe work practices, clearly understood and fairly enforced disciplinary procedures, and management accountability go hand-in hand, there is little opportunity to push workers into taking short cuts. OSHA not in any way suggesting harsh or punitive measures in lieu of the elimination or control of physical hazards. OSHA concludes that an organizational discipline exists for all levels of personnel at a worksite and believes that the application of that system to safety and health program activities is an important and appropriate concern for OSHA in the provision of safety and health management guidelines.

Therefore, the language concerning discipline and enforcement is retained in paragraphs c 3 i and c 4 ii. An elaboration of its rational is included in the Commentary.

Several commentors objected that employers can never perfectly ensure that all employees understand all rules, responsibilities, and procedures. It is OSHA's experience that the quality, content, and success of training vary widely. The act of training itself is not the result that OSHA recommends for effective worker protection. OSHA recognizes the natural limits of communication and comprehension, and agrees that some reasonable interpretation of the phrase "ensure understanding" must be applied.

The term used in the guidelines is intended to convey a need for the individuals to verify by some reasonable means that hazard information and the necessary elements of a safety and health program are understood by the people who must deal with them.

This can be done by formal testing, oral questioning, observations, or other means. In fact, observation and interviewing of employees are key methods used by OSHA in VPP reviews to determine, among other thins, the quality of employee safety, health, and emergency training.

The term is intended to convey the same diligence that would be applied to ensuring an understanding of other operational requirements, such as time and attendance, production schedules, and job skills.

The Agency is retaining the words "ensure understanding" in paragraphs c 4 i , ii and iii. Some respondents from Federal Agencies expressed concern that the proposed guidelines might conflict with requirements for safety and health management already established by OSHA for Federal Government agencies Exhs , Before preparing the final version.

OSHA compared the proposed guidelines to existing Federal Agency requirements, its instructions to compliance officers for determining whether to do full or partial inspections based on safety and health program management, the requirements of the VPP, and the 7 c 1 consultation safety and health program elements. The expanded sub-element on employee reports of hazards and the explanation added to the sub-element on employee involvement concerned protection from discrimination resulted in part from those comparisons.

With these additions. OSHA concluded that, while these guidelines may lead to adjustments in the other policies reviewed, they pose no fundamental conflict with those policies. To avoid confusing duplication. OSHA has decided not to include areas which are fully covered by regulation. No language concerning recordkeeping was added to the guidelines.

The guidelines do, however, deal with the effective use of occupational injury and illness data, See c 2 v. Some commentors stated concerns with the use in the proposed guidelines of "OSHA advises.

The use of the word "encourage" was suggested as an alternative Exhs. OSHA does not agree that the use of "advise" constitutes a requirement: rather it indicates advice which may or may not be accepted. OSHA has, however, added the words "and encourages" to "advises" in paragraph a 1 , to ensure that employers understand the voluntary nature of the guidelines.

One commentor suggested that "facility" be added to the guideline language on preventive maintenance of equipment Exh. OSHA agrees and has expanded preventive maintenance to include the facility as well as equipment in paragraph c 3 ii. Paragraph c 2 i B , concerning analysis prior to use, was also changed to include "facility. A commentor suggested that OSHA make clear the necessity of safety and health training prior to the assumption of duties Exh.

OSHA rulemaking records are replete with evidence supporting the need for such training. Consequently, such language has been included in the Commentary on employee training. Based on its own further review, OSHA has made several additional changes.

In this same sub-element, the reference to "phrase hazard analysis" has been dropped, because it is primarily relevant to construction. The guidelines are therefore published as a notice. Accordingly, pursuant to the authority of the Assistant Secretary, the following guideline is published. Signed at Washington, DC this nineteenth day of January, Scope and Application. The Occupational Safety and Health Administration OSHA has concluded that effective management of worker safety and health protection is a decisive factor in reducing the extent and the severity of work-related injuries and illnesses.

Effective management addresses all work-related hazards, including those potential hazards which could result from a change in worksite conditions or practices. It addresses hazards whether or not they are regulated by government standards. OSHA has reached this conclusion in the course of its evaluation of worksites in its enforcement program, its State-operated consultation program, and its Voluntary Protection Programs.

These evaluations have revealed a basic relationship between effective management of worker safety and health protection and a low incidence and severity of employee injuries. Such management also correlates with the elimination or adequate control of employee exposure to toxic substances and other unhealthful conditions.

OSHA's experience in the Voluntary Protection Programs has also indicated that effective management of safety and health protection improves employee moral and productivity, as well as significantly reducing workers' compensation costs and other less obvious costs of work-related injuries and illnesses. Through an analysis of public comment received in response to its request and through an earlier review of literature. OSHA has found that the conclusions it has reached from its own experience are supported by a substantial body of expert and practitioner opinion.

Based on this cumulative evidence that systematic management policies, procedures and practices are fundamental to the reduction of work-related injuries an dillnesses an dtheir attendant economic costs.

OSHA offers the following guidelines for effective management of worker safety and health protection. OSHA urges all employers to establish and to maintain programs which meet these guidelines in a manner which addresses the specific operations and conditions of their worksites. It will seek to prevent injuries and illnesses, whether or not compliance is at issue.

As the size of a worksite or the complexity of a hazardous operation increases, however, the need for written guidance increases to ensure clear communications of policies and priorities and consistent and fair application of rules. An effective occupational safety and health program will include the following four elements. To implement these elements, it will include the actions described in paragraph c. The recommended practices use a proactive approach to managing workplace safety and health.

Traditional approaches are often reactive —that is, problems are addressed only after a worker is injured or becomes sick, a new standard or regulation is published, or an outside inspection finds a problem that must be fixed. These recommended practices recognize that finding and fixing hazards before they cause injury or illness is a far more effective approach.

The idea is to begin with a basic program and simple goals and grow from there. If you focus on achieving goals, monitoring performance, and evaluating outcomes, your workplace can progress along the path to higher levels of safety and health achievement.