Enforcement of safety regulations has increased over the past few years, and so have the related fines. We are seeing clear evidence of the results in the Kansas City area. For example, a local firm recently paid $6,000 for simply failing to report an injury requiring hospitalization within 24 hours.
If you’re like most companies, you have excellent intentions for your safety program. But if you haven’t invested enough time or resources on it, you could be out of compliance – and paying the price in both dollars and employee productivity.
3 signs your safety program needs work
- Your written documentation is out of date. The quickest way to check on the timeliness of your current safety documentation is to look for a plan to address the Walking and Working Surfaces regulation that went into effect in January 2017. This new regulation requires inspections of walking and working services and addresses ladders, anchoring and other factors. You can also look for information about the global harmonization and hazard communication regulations that came out a few years ago. If you have not added these to your plan, you’re probably out of compliance.
- Your incident rate is higher than your industry’s. Also look at your experience modification rate or EMR. Is it above or below 1? And which way is it trending? If it’s under 1 and holding steady or going down, you’re probably in good shape. If it’s near 1 or creeping upward, you probably need to address it. And having a high EMR doesn’t just mean you pay more for insurance. It can also exclude you from new revenue opportunities.
- You’re lacking in training and training documentation. Failing to train employees on a regular basis is a sure-fire sign that your safety program needs work. Documenting the training also goes a long way toward passing an OSHA inspection.
Inspections and investigations are easy ways to prevent incidents
One of the most common safety program errors we see is failing to anticipate and manage for safety risks. You should be scheduling, performing and documenting facility inspections on a weekly or more frequent basis to spot safety issues before they cause a problem. Investigating near misses also is a good idea. Both tactics are inexpensive and can take only a handful of minutes per day. If they prevent just one slip, trip or fall, they can save you a bundle.
Address distracted driving
Distracted driving – thanks to smartphones – is one of the fastest growing causes of tragic injury and loss of life. It also can cost you financially, especially if you haven’t established and enforced a distracted driving program. I’ve seen studies showing that talking on the phone while driving – even hands-free – increases your risk of collision by 400%. Texting while driving doubles that risk. So be sure to create, document and communicate expectations and consequences for talking and texting while driving. You might even want to consider requiring drivers to download a free app that prevents their phones from being answered while they’re in motion.
Want to take your program up a notch?
Even if you think your program and your safety experience are strong, you’d be wise to evaluate your program every other year. To improve more, look at what your competitors are doing that you aren’t. If your programs and documentation are buttoned up, turn your attention to employee communication. That area can always be improved.
Construction Sites at Greatest Risk
Construction companies are at greater risk of a surprise safety inspection than companies in other industries, because inspectors can see a hazard while they’re driving by construction sites. Also, many construction sites have multiple companies and ever-changing work environments, so there’s a greater opportunity for visible violations to occur. Inspectors can take photos and document a safety violation without even entering the site.
Prepare for an OSHA inspection
To prepare for an unexpected visit, ensure you are in compliance and that your written programs and documentation are up to date. Then, when the OSHA inspector shows up, take a deep breath! Be polite and ask the inspector to take a seat. Call the person in charge of your safety program. And stop work if you are involved in a high-hazard situation.
If you’re concerned about that possibility, consider walking your leadership team through an exercise to discuss what you would do if an inspector showed up tomorrow. After all, an ounce of prevention is worth a pound of cure. It’s a great step forward in getting your safety practices up to snuff.
By Dennis Collins, CSP, Safety Consultant