Your site is OSHA-compliant — is that good enough?
Your site is OSHA-compliant — is that good enough?
For some, focusing on OSHA compliance may mean missing risks
If striving for 100% compliance with Occupational Safety and Health Administration (OSHA) safety requirements is an ongoing struggle at your workplace, you probably won't like what Deborah R. Roy, MPH, RN, COHN-S, CET, CSP, FAAOHN, has to say about it.
"One hundred percent compliance with OSHA won't eliminate workplace injuries, illnesses, and fatalities," she says. "And it was never intended to."
Too many workplaces focus on OSHA compliance and don't make enough of an effort to identify the risks associated with their own environments and employment populations, she says.
"OSHA regulations are a minimum standard, not the ideal standard," says Lee, president of SafeTech Consultants in Portland, ME. "They were developed by OSHA in response to complaints about the high rate of on the job fatalities, but were never intended to be the ultimate safety system."
100% compliant not 100% safe
Lee frequently speaks to groups about the difference between compliance and best practices, and illustrates her point with Bureau of Labor Statistics data from the U.S. Department of Labor. When workplace fatality data are lined up with OSHA safety regulations, she points out, more than 50% of the deaths are not even addressed by OSHA regulations. The first OSHA standards were published in 1971.
"That's because most [of the deaths not addressed by OSHA standards] are due to transportation accidents and workplace violence, and neither is addressed by OSHA standards," she explains. "That's one big example of why one hundred percent compliance with OSHA regulations will not result in zero workplace fatalities."
That's not to say that OSHA standards have not had a clear impact on workplace deaths. In 1970, there were 56 million workers in the United States, and 13,800 worker fatalities (according to Department of Labor data). In 2004, by contrast, there were 138 million workers and 5,700 deaths; however, there were 4.3 million work-related injuries and illnesses, a rate that has a huge impact on productivity and business economics, as well as the individual effects to those sickened and injured.
Focusing solely on complying with OSHA regulations, Lee points out, can mean employers are not identifying the risks around them and eliminating openings for injuries and illnesses.
If a company spends time on compliance with standards for which lack of compliance has not resulted in injury, that's time and effort misdirected, Lee says. It is possible, even though incongruent, to be fully compliant with OSHA regulations and not have a safe workplace; likewise, it is possible to have a safe workplace and yet be out of compliance and subject to citation by OSHA.
Possible to have it all
"It is possible to accomplish both [OSHA] compliance and safety," Lee insists. "The concept is to really look beyond OSHA compliance, and rather than looking at it as the level to achieve, strive to achieve a more comprehensive health and safety program."
While assessing operations in pursuit of compliance with federal standards, Lee says occupational health and safety professionals should be assessing the hazards inherent in their operations. In some cases, hazards present in the workplace are addressed by OSHA standards but, as Lee has pointed out, sometimes they are unrelated to any OSHA standard.
For that reason, Lee suggests companies develop safety systems based on risk in their own specific industry, not simply based on existing regulation.
The European Union uses a management systems approach to workplace safety, leaving evaluation of risk—and the decisions made to reduce risk—up to company management to decide. This management systems approach is a method of integrating day to day operations, safety goals, performance targets, risk assessments, rules and procedures, and monitoring and evaluation processes. Decisions on workplace safety are based on an evaluation of risk rather than on-set standards.
Here in the United States, Lee says, the idea of management systems is evident in OSHA's Voluntary Protection Program (VPP) and the Maine Top 200 Program, both of which center on eliminating risks and creating a safe work environment, rather than concentrating all attention on avoiding OSHA penalties. The Maine Top 200 program, similar to VPP, was created by OSHA in Maine, in which companies with good safety records could join a voluntary program and learn to do self inspections, and take responsibility for planning and implementing health and safety improvements.
"You can do both [compliance and best safety practices], because in theory, if the OSHA standards make sense, as you identify risks you'll find things that aren't compliant," she says. "If you have a fleet of trucks, there's your risk, but that's not something OSHA standards address."
A common mistake companies make by mapping their safety systems on OSHA is focusing on the safety of their employees without paying attention to contractor safety.
"That's a big hole for most employers," Lee says. "If it's not their own employees, they sort of ignore them, even if it [contractors' actions] can affect their employees."
Measure organization's unique safety risk
For evaluating safety and health risks, Lee likes to use a program evaluation profile (PEP) form developed by OSHA a decade ago. (Note: OSHA no longer uses the PEP form, but it remains accessible at the administration's website: www.osha.gov/SLTC/safetyhealth/pep.html.) The PEP format has the evaluator grade the organization in six areas:
Management leadership and employee participation — Visible management leadership in an effective safety and health program for both regular employees and contractors; employee participation in their own protection.
Workplace analysis — Survey and hazard analysis; inspection; hazard reporting system.
Accident and record analysis — Investigation of accidents and near-misses; analysis of injury and illness records.
Hazard prevention and control — Hazard control; facility and equipment maintenance; suitable medical program.
Emergency response — Appropriate emergency planning, training, drills, and equipment; first aid and emergency care readily available.
Safety and health training — Training that includes all subjects and areas necessary to address hazards at the site.
Each area is assigned points based on whether the organization's practices are outstanding, superior, basic, developmental, or absent/ineffective.
"With the PEP form, you can do a self-evaluation and look at where the holes are," Lee explains.
She says the first time she spoke to an audience of safety experts on simple compliance versus best practices, she was surprised to find out how many had not approached safety from that standpoint.
"I didn't get it — they should have already been there," she recalls. "There are a lot of companies doing a good job with their safety systems, but plenty out there for whom this is new information."
For Information:
Deborah R. Roy, MPH, RN, COHN-S, CET, CSP, FAAOHN, president, SafeTech Consultants, One Monument Way, 2nd Floor, Portland, ME 04101. Phone: (207) 773-5753. Email: [email protected].
Occupational Safety and Health Administration Safety and Health Programs Program Implementation. More information available at www.osha.gov/SLTC/safetyhealth/evaluation.html.
U.S. Food and Drug Administration, "Maine Top 200" occupational health case study. Available at www.fda.gov/cdrh/leveraging/03c.html.
If striving for 100% compliance with Occupational Safety and Health Administration (OSHA) safety requirements is an ongoing struggle at your workplace, you probably won't like what Deborah R. Roy, MPH, RN, COHN-S, CET, CSP, FAAOHN, has to say about it.Subscribe Now for Access
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