5 steps to boost safety and avoid OSHA citations
You’re doing all you can to improve employee training, awareness, and engagement. But are these the things that are really going to bring your incident numbers down? Keep reading to learn what an occupational safety and health lawyer recommends.
Attorney Valerie Butera, an OSHA specialist with the national law firm Epstein Becker Green, notes that while it’s impossible to mitigate against every conceivable workplace hazard, taking five critical steps can help improve safety and avoid costly OSHA citations. Here’s what she recommends:
(1) Conduct an internal safety and health audit under attorney-client privilege. Working with a safety and health professional, employers should closely examine every aspect of the workplace to ensure they’re in full compliance with OSHA standards and best practices. Butera says employers can protect internal audit reports from disclosure to OSHA by working with counsel and OSH professionals to conduct the audit.
(2) Create a strong safety culture. Management at all levels should be involved in creating the culture by actively communicating with employees and being physically present where employees work. Make sure employees know that safety is a priority over production and that suggestions for improvement are welcome at your place of business.
(3) Make sure that safety and health documentation is current and well communicated. Every employer should regularly review its OSHA documentation requirements, including recording of work-related injuries and illnesses, as requirements can change from time to time. Also, make sure relevant employees fully comprehend the documentation, know how and when to use it, and understand the reasons for maintaining it.
(4) Conduct regular and comprehensive training. Train employees regularly and comprehensively. OSHA does not hesitate to cite employers for failure to train, but Butera says this is an avoidable problem. Also, make sure you’re training in a way that employees can fully comprehend, as the law requires. One way to do this is to give a quiz at the conclusion of the training, which requires employees to demonstrate their understanding. If employees are unable to reach the expected score on the first try, retrain and give the quiz again. Keep all records of training as well as quizzes and other materials.
(5) Protect contractors and temporary workers, too. OSHA has instructed its compliance officers to expand the scope of inspections to include temporary workers. This instruction led to a 322 percent increase in inspections involving temporary employees in 2014, according to Butera. Most citations were issued to host employers (rather than temporary agencies) for failing to train or provide temps with the safety gear they provide to permanent employees.