Kevin Ian Schmidt

How to Put Together a Workplace Safety Training Workshop

Putting on a workplace safety training workshop is a great way to prepare your employees for an emergency situation. This training workshop will need to include both general safety training for your industry, as well as specific safety training for hazards that directly impact your company, job sector, location. These training workshops need to be given to all of your employees, however, you can offer several sessions to make the group size more manageable.

5 Steps to a Successful Safety Training Workshop

classroom safety trainingStep #1 – Determine What General Safety Issues to Deal With

The first step is to determine what general safety procedures you want to teach your employees about. Common safety issues include medical emergencies, building security and fire emergencies. A good way to handle these training needs is to bring in a professional for each type of general safety issue. For example, you can bring in an instructor to teach employees CPR and general first aid, you can have the fire department put on a demonstration about fire safety and you can have your security company come in to teach your employees how to use the security system and how to stay safe.

Step #2 – Determine Hazard Specific Issues to Teach

The next step is to determine company specific hazards to deal with in your training workshop. For example, if your company works with hazardous materials like chemicals, then you will need to include an OSHA standards training segment that deals with the proper handling and safety protocols for chemicals. On the other hand, if you utilize heavy machinery, then you will want to include a segment on proper use of machinery, safety precautions for machine use and what to do if a body part or a foreign object gets caught in the machine.

Read: 10 Reasons Why Safety Training is Often Ineffective

Step #3 – Scheduling Concerns

After you have the format and topics of your workplace safety training workshops in place, your next step is to figure out how to set up the schedule. If you only have a few safety issues to cover then you can schedule one long workshop, however, if there are a lot of safety issues to cover then you will want to divide the issues into several workshops. Another scheduling concern you need to figure out is how to get all of your employees to attend the workshops without leaving your business unsupervised. You have a couple of options. Your first option is to schedule several repeat workshops that allow employees to be scheduled to attend the workshop in groups. Your second option is to hold one workshop for all employees on a day when the business is closed.

Step #4 – Put Together Your Training Materials

You need to put together training material for the workshop. This material will include instructions for responding to and managing specific safety issues, general information about each safety issue and a quiz. The material needs to be organized in a binder or folder, and one set of training materials needs to be published for each employee.

The EHS Center has FREE pre-made trainings

Step #5 – Testing Your Employees

To ensure your employees have mastered the safety strategies in each segment of your training workshop you need to test them. A simple multiple choice quiz at the end of each segment is sufficient. After passing all of the quizzes you can award each employee with a certificate of completion.

small business safety

Guide to OSHA Requirements for Small Businesses

Safety is good business and good for business. For the small business owner, initiatives taken to ensure employee and workplace safety are not only the right way to conduct business, but can result in lower costs, increased productivity, healthier profit margins,  and overall stronger employee morale.

What does OSHA require for small business owners?

OSHA maintains a set of six guidelines that are common to most general industry employers. These procedures protect yourself, your assets, the public you are in contact with in the course of your business and any employees you may be carrying.

1. Hazard Communication Standard

If your business uses or comes into contact with any material that is determined to be hazardous, as an employer it is your responsibility to make this known, mark the area clearly and have a plan in place to deal with any emergencies.

You must inform and maintain regular training of your employees regarding the proper use or disposal of any hazardous chemicals , as well as keep any storage areas well-maintained and inspected on a regular basis.

Learn more about the hazard communication standard

2. Emergency Action Plan Standard

Depending on the physical size of your business location and the number of employees you may have, OSHA mandates that an emergency plan be available and ready to implement. The plan describes the expectations of both yourself, as the employer, and what your employees need to do to ensure their safety.

The EHS Center has free components of emergency action plans that might help your company develop a comprehensive plan, check out their free offerings here

Included in this would be a visible evacuation plan, a means to report fires or other emergencies, a guide to any critical business operations that must be done during an emergency and a method to account for all employee whereabouts during the emergency.

Learn more about Emergency Action Plans

3. Fire Safety

Employers must have a fire prevention plan that addresses the potential areas that a fire could initiate in, such as fuel sources or flammable chemicals. The plan also must address the requirement to install fixed extinguishing systems, such as overhead sprinklers, alarm systems and multiple portable extinguishers that are marked and inspected regularly.

Learn more about workplace fire safety

4. Exit Routes

All exit routes must be marked and available for emergency use. Exit access must be free from obstructions and unlocked. Normally, a workplace must have two exits at a minimum, but depending on the location of your business or the number of employees you have, additional exits may be required.

Learn all about OSHA standards for emergency exits

5. Walking / Working Surfaces

All businesses have areas that must be kept clean, free from debris and well maintained. This includes floors, aisles, stairways, ladders and platforms. Most accidents result from falls on ground surfaces or falls from elevated surfaces.

Make sure all surfaces are free from anything that could cause a fall and that all stairways have the correct amount of railings. Any scaffolding or powered manlifts must be properly working.

If you are conducting your business out of your home, these same standards apply. Make sure entrances are free from debris and uneven steps or holes, and that required handicapped access ramps are also easily accessible.

The EHS Center offers slip, trip, and fall program components for free here

6. Medical and First Aid

Medical and first-aid supplies must be kept on-hand and must be available to employees. As an employer, you need to expect that accidents will happen and be ready to address concerns, either minor or major ones.

Learn about OSHA requirements for first aid supplies and medical response

The above six standards apply to any workplace environment, including small business owners. For more information on OSHA requirements, as well as protecting yourself from liability claims, review the OSHA Handbook for Small Businesses.

Process Safety Management Basics

Unexpected releases of toxic, reactive, or flammable liquids and gases in processes involving highly hazardous chemicals have been reported for many years. Incidents continue to occur in various industries that use highly hazardous chemicals which may be toxic, reactive, flammable, or explosive, or may exhibit a combination of these properties.

Regardless of the industry that uses these highly hazardous chemicals, there is a potential for an accidental release any time they are not properly controlled. This, in turn, creates the possibility of disaster.

Record Disasters

Several major disasters involving highly hazardous chemicals drew international attention to the potential for major catastrophes; the public record in the U.S. is replete with information concerning many other less notable releases of highly hazardous chemicals.

Hazardous chemical releases continue to pose a significant threat to employees and provide impetus, internationally and nationally, for authorities to develop or consider developing legislation and regulations to eliminate or minimize the potential for such events.


On July 17, 1990, the U.S. Dept. of Labor, OSHA issued the “Process Safety Management of Highly Hazardous Chemicals” (PSM) (29 CFR 1910.119), containing requirements for the management of hazards associated with processes using highly hazardous chemicals to help assure safe and healthful workplaces.

OSHA’s PSM standard emphasizes the management of hazards associated with highly hazardous chemicals and establishes a comprehensive management program that integrates technologies, procedures, and management practices.

The Clean Air Act Amendments and the PSM Standard

Shortly after the publication of OSHA’s proposed PSM standard, Congress enacted the Clean Air Act Amendments (CAAA) which contained revisions to the Clean Air Act of 1990.

Section 304 of the CAAA requires that the Secretary of Labor, in coordination with the Administrator of the Environmental Protection Agency (EPA), promulgate a PSM standard to prevent accidental releases of chemicals that could pose a threat to employees.

The CAAA also requires that the PSM standard include a list of highly hazardous chemicals which includes toxic, flammable, highly reactive, and explosive substances.

CAAA Requirements for the PSM Standard

The CAAA requires that the standard include a list of highly hazardous chemicals which includes toxic, flammable, highly reactive, and explosive substances. These requirements have become widely known as the “14 PSM Program Elements.

OSHA’s Final PSM Standard

The final PSM standard was promulgated in 1992 and requires the employer to incorporate each of the 14 key elements in a formal PSM program. The key provision of final PSM standard is process hazard analysis (PHA)—a careful review of what could go wrong and what safeguards must be implemented to prevent releases of hazardous chemicals. Employers must identify those processes that pose the greatest risks and begin evaluating those first.

PSM clarifies the responsibilities of employers and contractors involved in work that affects or takes place near hazardous processes to ensure that the safety of both plant and contractor employees is considered.

The standard also mandates written operating procedures; employee training; pre-startup safety reviews; evaluation of mechanical integrity of critical equipment; and written procedures for managing change. PSM specifies a permit system for hot work; investigation of incidents involving releases or near misses of covered chemicals; emergency, action plans; compliance audits at least every three years; and trade secret protection.

Benefits of an Effective PSM Program

Effective PSM helps ensure the proper development of plant systems and procedures to prevent unwanted releases which may ignite and cause toxic impacts, local fires, or explosions in plants and installations.

PSM can also improve:

  • the operability, productivity, stability, and quality of the outputs of hazardous chemical processes; and
  • the design and specification of safeguards against undesirable events.

Effective PSM results in tangible benefits such as reduced exposure to lawsuits, OSHA penalties, public liability claims, and hikes in workers compensation insurance premiums.

Other intangible benefits include higher morale, increased trust, and an improved corporate image – the community sees the company as a responsible corporate citizen.

The final PSM standard mainly applies to manufacturing industries – particularly, those pertaining to chemicals, transportation equipment, and fabricated metal products. Other affected sectors include natural gas liquids; farm product warehousing; electric, gas, and sanitary services; and wholesale trade. It also applies to pyrotechnics and explosives manufacturers covered under other OSHA rules and has special provisions for contractors working in covered facilities.

The various lines of defense incorporated into the design and operation of the PSM process should be evaluated and strengthened to make sure they are effective at each level. Process safety management is the proactive identification, evaluation and mitigation or prevention of chemical releases that could occur as a result of failures in processes, procedures, or equipment.

What is a “process?”

To understand PSM and its requirements, employers and employees need to understand how OSHA uses the term “process” in PSM.

  1. Any group of vessels which are interconnected, and
  2. Separate vessels which are located such that a highly hazardous chemical could be involved in a potential release

For purposes of this definition, any group of vessels that are interconnected, and separate vessels located in a way that could involve a highly hazardous chemical in a potential release, are considered a single process.

What industries does PSM focus on?

The process safety management standard targets highly hazardous chemicals that have the potential to cause a catastrophic incident.

OSHA’s standard applies mainly to manufacturing industries–particularly those pertaining to chemicals, transportation equipment, and fabricated metal products.

Other affected sectors include those involved with:

  • natural gas liquids
  • farm product warehousing
  • food processing
  • electric, gas, and sanitary services
  • wholesale trade
  • pyrotechnics and explosives manufacturers

It has special provisions for contractors working in covered facilities.

Who is Not Covered by the PSM Standard?

The PSM standard does not apply to the following:

  • retail facilities;
  • oil or gas well drilling or servicing operations;
  • normally unoccupied remote facilities;
  • hydrocarbon fuels used solely for workplace consumption as a fuel (e.g. propane used for comfort heating, gasoline for vehicle refueling), if such fuels are not a part of a process containing another highly hazardous chemical covered by this standard; and
  • flammable liquid stored in atmospheric tanks or transferred which are kept below their normal boiling point without benefit of chilling or refrigerating and are not connected to a process

To control these types of hazards, employers need to develop the necessary expertise, experience, judgment, and initiative within their work force to properly implement and maintain an effective process safety management program as envisioned in the OSHA PSM standard


OSHA General Duty Clause

As detailed in the Section 5 (The General Duty Clause) of the OSHA Act, the employer is assigned responsibility and held accountable to maintain a safe and healthful workplace. The following is an excerpt from Public Law 91-596, 91st Congress, S. 2193, December 29, 1970.

Section 5

(a) Each Employer –

  • (1) shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees;

  • (2) shall comply with occupational safety and health standards promulgated under this act.

Employers can be cited by OSHA for violation of the General Duty Clause if a recognized serious hazard exists in their workplace and the employer does not take reasonable steps to prevent or abate the hazard. The General Duty Clause is used only where there is no standard that applies to the particular hazard.


OSHA-Mandated Responsibilities

As you can see, employers have clearly defined responsibilities under OSHA, and as the “agent of the employer” the supervisors have the same responsibilities for the employees they supervise. The following list are basic responsibilities stated throughout OSHA standards.

  • Provide employees a workplace free from recognized hazards. It is illegal to retaliate against an employee for using any of their rights under the law, including raising a health and safety concern with you or with OSHA, or reporting a work-related injury or illness.
  • Comply with all applicable OSHA standards.
  • Report to OSHA all work-related fatalities within 8 hours, and all inpatient hospitalizations, amputations and losses of an eye within 24 hours.
  • Provide required training to all workers in a language and vocabulary they can understand.
  • Prominently display this poster in the workplace.
  • Post OSHA citations at or near the place of the alleged violations.

Identifying Hazards

The employer is responsible for identifying hazards. It’s useful to categorize them into four categories:

  • The first three categories (materials, equipment, and the environment) represent hazardous conditions. Hazardous conditions are the surface causes directly account for only a small percentage of all workplace accidents.
  • The fourth category (people) describes employee behaviors. Employee behaviors represent the surface causes that contribute to or cause a higher percentage of workplace accidents.

 They are the root causes that ultimately contribute to or cause most accidents.

Let’s review these four categories:

Materials: liquids, solids and gases that can be hazardous to employees.

  • Liquid and solid chemicals (such as acids, bases, solvents, explosives, etc.) can produce harmful effects.
  • Raw materials (solids like metal, wood, and plastic) used to manufacture products are usually bought in large quantities and can cause injuries or fatalities in many ways.
  • Gases, like hydrogen sulfide and methane, may be extremely hazardous if leaked into the atmosphere.

Equipment: machinery and tools used to produce or process goods.

  • Hazardous equipment that is improperly guarded and places workers in a danger zone around moving parts could cause injury or death.
  • Lack-of a preventive and corrective maintenance will make it difficult to ensure equipment operates properly.
  • Tools that are not in good working order, improperly repaired, or not used for their intended purpose is only an accident waiting to happen.

Environment: general area that employees are working in.

  • Poor facility design, hazardous atmospheres, temperature and/or noise can cause stress.
  • If areas in your workplace are too hot, cold, dusty, dirty, messy or wet, then measures should be taken to minimize the adverse conditions.
  • Extreme noise that can damage hearing should not be present.
  • Workstations may be designed improperly, contributing to an unsafe environment.

People: employees, managers, supervisors, in the workplace.

  • Unsafe employee behaviors include taking short cuts or not using personal protective equipment.
  • Employees who are working while fatigued, under of influences of drugs or alcohol, distracted for any reason, or in a hurry are “walking and working hazards.”

There is one sub-catergory that is often able to be added, especially when building up a safety culture, and that is:

Supervision: this is managers, supervisors, directors, top down issues.

  • Management may unintentionally promote unsafe behaviors. For example, they may ignore unsafe work practices.
  • Inadequate or missing safety plans, programs, policies, processes, procedures, practices, and rules (written and unwritten) may somehow result in injury, illness, or death in the workplace.
  • Not training employees how to work safely
  • Not supplying employees with the right tools for the right job.
Want to learn more about Root Cause Identification? Check out the EHS Center to learn more.

Surface Cause Analysis – Why did the accident occur? Here you determine the unique hazardous conditions and unsafe behaviors that interacted to produce the accident. Each of the hazardous conditions and unsafe behaviors uncovered are the surface causes for the accident. They give clues that point to possible root causes/system weaknesses. Examples of surface causes include:

  • A broken ladder
  • A worker removes a machine guard
  • A supervisor fails to conduct a safety inspection
  • A defective tool

Root cause analysis – Why did the surface causes occur? At this level, you’re analyzing the weaknesses in the safety management system that contributed to the accident. These weaknesses are inadequate/missing safety components such as policies, programs, plans, processes, procedures, or practices. Examples of root causes include:

  • Inadequate or missing safety management system components.
  • Inadequate performance or failure to carry out system components such as: failure to train, failure to provide PPE, and inadequate implementation of safe procedures.
  • Failure to enforce safety rules, discipline for safety infractions or recognize safe performance.
  • Failure to conduct safety inspections, JHAs, and incident/accident investigations

Tolerance for Cash Shortages – Terrible or Bearable?

If you lost 5% or more of your sales and it just can’t be explained how it occurred, would it bearable or terrible to the financial health of your business?

Shortages in cash may be somewhat understandable. Cashiers handle cash transactions, credit cards, gift cards, checks, traveler’s checks, and any number of discounts and coupons.

When transactions go awry for some reason, they must void, no sale, refund, discount, or reduce the price in some way. During interactions with the public they may encounter attempts at credit or gift card fraud, bad checks, counterfeit, price changing, quick change schemes, drive-offs, walk-offs or some other new scam of the day.

The cashier is expected to know all of these transactions, handle them flawlessly, and yet have a perfect cash drawer at the end of the shift. But what if they don’t? What if the cash is short? And how much does the cash till have to be short to get your attention? Some owners and/or managers create a policy that shortages must be paid back. There are many reasons why this is not a sound policy, and against the law in some states.

Frequent cash drawer overages are not desirable either. Overages may be indicative of poor cash management or worse, manipulation of the cash operation and theft.

So, what amount of cash shortage, or overage, is acceptable within the framework of your business? Knowing that a perfectly balanced cash drawer is not practical in a blind remittance procedure, what is bearable? More importantly, are cash handling policies written, performance expectations clear and disciplinary actions for excessive cash overages and shortages fair and consistent?

Establishing “Bearable”

  • Policies and procedures – Establish written policies, procedures, and expectations in handling transactions. They should include before and after shift count verification, single drawer accountability, manager authorizations for voids, refunds, over rings, and closing the cash drawer after every transaction. Calculators and unauthorized credit cards “skimming” devices near the cash registers must be prohibited and stated in policy.
  • Blind remittance – At the end of their shift, cashiers should not be privy to cash totals on the ‘Z’ tape as they countdown their cash till. They should report what they have in their till, minus the beginning bank.
  • Communicate Expectations – Communicate cash management and security related expectations via written memo, employee handbook, and as part of everyday operations.
  • Signed cashier policies – Have every cashier sign cash handling expectations. Retain in their individual personnel files.
  • Making Change – Teach cashiers the habit of counting back change to the customer.
  • Cash shortages and overages – Establish a tolerable dollar amount of cash shortage or overage. Some companies have established a $3-5 range per individual cash drawer per cashier depending on the number of cash transactions and total sales per shift. Set an aggregate amount over the course time as well; i.e. .1% of sales each month.
  • Establish acceptable level of exceptions – Set acceptable performance standards in the number and dollar amount in percentage to sales for voids, over rings, refunds, no sales, check average, and others that are pertinent to your business.
  • Cash drops – Managers should remove excess cash and large bills from the cash register and place in the safe.
  • Train – Train cashiers on how to handle all transactions, including handling suspected counterfeit, and the common scams involving credit/gift cards and quick change.

After policies and procedures are established, expectations are clearly communicated, and cashiers are properly trained, it’s time to routinely evaluate their performance. Emphasis should be placed on operating the cash function with minimal errors. When errors do occur and the cash handling performance is not within established guidelines, the appropriate action should be taken to correct the behavior or performance and get them in compliance. If the individual cashier’s performance is routinely outside of the established acceptable performance levels, they move into “terrible” and must be dealt with accordingly.

Check out: Tips to Identify Internal Theft

Dealing with Terrible

  • Formal cash management reviews – Establish a formal cash management performance review process. (Daily, Weekly, Monthly)
  • Progressive Discipline – Implement progressive discipline process consisting of warnings, written reprimands, and terminations for poor cash handling performance that is not in compliance with acceptable standards.
  • Investigations – Investigate large unexplained shortages or overages to determine the cause. Unexplained large discrepancies should enter the progressive discipline process at a higher, more serious level, i.e. Suspension, Termination.
  • Retrain – Retrain cashiers that are not in compliance with performance standards.
  • Reassign – Reassign cashiers that are not in compliance with cash management standards to a non-cash position, if available.
  • Policies and procedures – Reevaluate policies and procedures relating to cash management, security processes, and disciplinary measures and make adjustments according to the needs of your business.

Handling customer transactions is a tough job, even for the most experienced, conscientious cashier. Mistakes happen and unexpected shortages and overages occur. The key to successful cash management operations is to have sound policies and procedures, clear expectations, routine audits, and fair and consistently applied progressive discipline. Your shortages will quickly respond from “terrible” to “bearable”, increase profitability, and make you more competitive in the marketplace.

Basics of Fleet Safety

A fleet of vehicles for a company can be a hidden cause of shrink, can drive accidents, and/or can cost extra in insurance.

Logistics and trucking companies often understand this, often knowing to focus on fleet safety, but many small businesses with only a few vehicles or large companies that don’t view their fleet as an integral part of their business, will miss the importance of a Fleet Safety Program.

Employers can take steps to protect their employees and their fleet.


  • Assign a key member of the management team responsibility and authority to set and enforce a comprehensive driver safety policy.
  • Enforce mandatory seat belt use.
  • Do not require workers to drive irregular hours or far beyond their normal working hours.
  • Do not require workers to conduct business on a cell phone while driving.
  • Develop work schedules that allow employees to obey speed limits and to follow applicable hours-of-service regulations.
Check out this Sample Fleet Safety Policy from Secura Insurance

Fleet Management

  • Adopt a structured vehicle maintenance program.
  • Provide company vehicles that offer the highest possible levels of occupant protection.

Safety Programs

  • Teach workers strategies for recognizing and managing driver fatigue and in-vehicle distractions.
  • Provide training to workers operating specialized motor vehicles or equipment.
  • Emphasize to workers the need to follow safe driving practices on and off the job.
Check out: Establishing a Fleet Safety Program

Driver Performance

  • Ensure that workers assigned to drive on the job have a valid driver’s license and one that is appropriate for the type of vehicle to be driven.
  • Check driving records of prospective employees, and perform periodic rechecks after hiring.
  • Maintain complete and accurate records of workers’ driving performance.

Source: NIOSH 2004-136:Work-related Roadway Crashes Prevention Strategies for Employers


An unmanaged fleet can cost your company profits, sometimes undetectable on the surface.

5 Myths about Employee Theft

The statistics of internal theft are staggering: 

Small businesses are particularly vulnerable since they don’t have the resources or the processes in place to avoid and/or detect fraud activity.  With no formal loss prevention programs in place, many owners and managers rely on their experience and expertise to react to incidences of employees stealing.   Others rely on their beliefs, perceptions and ideals that their employees would not steal from them for a number of reasons. The following are myths associated with those ideological thoughts:

My employees would not steal from me because …

1. They Like Me – While it is true that good relationships with the boss may deter a small percentage of employees from stealing, research has shown that dishonest employees are driven by a number of factors.  Loss Prevention professionals cite the presence of the Theft Triangle as the breeding ground for employee theft. When these elements are present in the workplace, employees may be tempted to steal or become involved in other counterproductive behaviors.

Theft Triangle
a)    Motive – Potential gain and use for the cash or product
b)    Opportunity – Ability to quickly and safely steal the cash or product
c)    Low Risk of Detection – Perception of low probability of getting caught

The employees may genuinely like the manager or owner, but if the three factors are present in the work environment, the temptation to steal may override friendship.

2.  They’re My Best Employees – Many managers and employers perceive that because certain employees are self-motivated, hard workers, they do not have any integrity issues.  They are above reproach simply because they exceed expectations in their performance.  And because of that belief, those employees are not scrutinized for compliance to the rules, nor suspected of counterproductive behavior or theft.  Without accountability to the rules, even the best of employees may take advantage and steal.

3.  I Show That I Trust Them – It is essential that trust be developed throughout any organization.  It is the foundation of every great relationship.  In the world of business, the trust must be validated with accountability.  Unfortunately managers and owners may interpret showing trust as not checking up on employees.  Without a check and balance process or audit system, employees may perceive that there is low risk of getting caught.  All incidences of employee theft violate trust.  Show your employees that you trust them, but follow up on the performance expectations you have established.

4.  They Have a Clean Background – Pre-employment background checks are significant in establishing a comprehensive loss prevention program.  Hiring employees without criminal convictions may be a good start in creating an environment of honesty and trust.  High integrity must permeate the organization.  With a culture devoid of strong policies and procedures supported by compliance processes and effective supervision, employees may steal with a compelling motive, opportunity and the perception that they won’t get caught.  The ACFE reports that of the 1388 internal frauds investigated by Certified Fraud Examiners in the past year, 87% of them were perpetuated by first time offenders.  They cited the lack of internal controls as the key factor in the crimes that triggered the criminal behavior.

5.  I Pay Them a Higher Wage – Assumptions are made that paying employees a higher wage than their counterparts with other companies will make them happy.  If employees are happy with their wages they won’t steal.  It’s another myth.

Sociological studies have shown that employees are influenced by the culture established by the work environment.:

  • Approximately 10% of the employees are morally incorruptible.  They don’t bend or break the rules.  They don’t steal given any opportunity to do so.
  • Additionally, approximately 10% of employees bend and break policies and procedures with regularity and are prone to steal.  They are the challenge of Human Resource personnel in medium and larger size businesses and a big problem for the smaller companies.
  • The remaining 80% of the employee’s behavior in the workplace is influenced by the culture and attitudes.

If the rules are clear and compliance is expected, employee behavior gravitates to following those rules.  If the counterproductive behavior of the small percentage of the problem employees is not addressed and allowed to flourish, other employees will be influenced by that behavior.

90% of the workforce can be positively influenced to compliant behavior with well written rules, clear expectations, and effective follow-up.

We want to believe that employees won’t steal from us.  We really do.  We use these reasons to support our views.  But, on their merits, these views are indeed myths.

Check out: Tips to Identify Internal Theft

Sociological studies on workplace behavior, criminal investigations on employee fraud, and anecdotal stories have proven that the workplace environment must be controlled to avoid counterproductive behavior and theft.

  • Policies and procedures must be well written.
  • Compliance to the rules and behavior expectations must be clear.
  • Internal controls must be established and audited.
  • Counterproductive behavior must be addressed effectively.
  • The elements of the Theft Triangle must be eliminated.

It must be known in the work environment that opportunities to steal are low and the probability of getting caught is high.  You then might be right when you say; my employees won’t steal from me.

What could possibly motivate these individuals to risk their career and livelihood to make a few thousand dollars?

  • Drastic life changes: Loss of a loved one through death, divorce, or separation is a devastating development for anyone. This could reduce the employee’s income stream and increase expenses. Faced with mounting bills, the employee seizes the opportunity to take small amounts of money. Often, they believe that they can pay it back without getting caught.
  • Living beyond their pay scale: The largest losses are typically due to embezzlers seeking to live beyond their means. They seek to live the good life but are unable to afford the goods and amenities on their own. Stolen funds are used to acquire pricey cars, homes, and luxury goods. The employee may take expensive vacations and engage in activities that cost more than what they can afford.
  • Opportunity: Employees may start out pilfering petty amounts because the opportunity presents itself. Customers may forget to claim their change or bookkeepers may find an opportunity to adjust the books without being noticed. Taking advantage of these opportunities may become habit-forming and soon spiral out of control.
  • Addictions: Individuals dealing with compulsive behavior that costs money are not good candidates for jobs that involve cash handling or accounting. Compulsions can overcome even the best intentions, and employees end up funneling business funds to feed gambling, drug, and other addictions.
  • Greed: Good old-fashioned greed drives trusted employees to exploit opportunities to take for themselves what has been entrusted for business purposes. Theft can take the form of funds diversion or appropriating equipment and other goods for their own use.
  • Bad apples who passed the screening process: The employment screening process should weed out candidates with criminal records, but sometimes a few will pass the vetting due to inadequate background research or glitches in records processing. Placed in a position of trust, these individuals may be plotting their scheme to steal from the company even at the outset.
  • Revenge: Perceived slights can drive employees to seek retribution by stealing from the company. An individual who is passed over for a promotion or lateral transfer to a preferred location or someone who takes a negative assessment too personally may feel that they are claiming what has been denied to them by stealing from the company.

Type of Employee Theft

The Small Business Chronicle noted that there are five common types of employee theft, and four of them can be grouped under the category of direct theft. These four types of employee theft are:

  • Cash Theft. As its name implies, this type of theft, most commonly seen in retail businesses, involves the theft of money and can be done in multiple ways. It does not just involve employees physically taking money out of the cash register; it also includes overcharging customers and keeping the difference for themselves.
  • Supply Theft. This type of theft entails taking company property without permission. Some employees choose to take a series of smaller items – such as pens or paper – which add up over time, while others go after larger items such as furniture or computers. If this is allowed to continue undisturbed, it can heavily cost your company in replacing the supplies.
  • Merchandise Theft. This type of theft occurs when employees swipe merchandise that is meant for the customer, whether it is done during the workday or during the distribution process. Like supply theft, this can easily add up over time and cost your business a great deal of money.
  • Information Theft. One of the less tangible forms of employee theft, this particular action occurs when employees forcibly obtain access to confidential information – such as customer lists – in order to use it for their benefit. In addition to potentially costing your business, this breach of confidentiality can cause distrust in your business.

Employee Fraud

There is one type of employee theft that was not mentioned in the previous section, and while this final category does not involve any physical theft, it is no less damaging to your company. In addition to taking money away from your business and negatively affecting your finances, employee fraud can irreparably damage your business’s reputation. Some of the prevalent types of employee fraud include:

  • Payroll Fraud. In this action, employees falsely claim compensation for work they have not done. This includes claiming reimbursement for non-work purposes and falsifying their time sheets.
  • Bribery and Corruption. Some employees have been found to accept bribes or other benefits from third parties in exchange for an advantage.
  • Asset Misappropriation. One of the most common types of employee fraud, this includes any activity that makes use of the company’s assets for personal gain. In addition to the physical thefts mentioned above, this also includes workers’ compensation fraud, paycheck forgery, and insurance fraud.



Establishing a Fleet Safety Program

Unlike other workplaces, the roadway is not a closed environment. Preventing work-related roadway crashes requires strategies that combine traffic safety principles and sound safety management practices.

Crashes are not an unavoidable part of doing business.

Accidents are more expensive than most people realize because of the hidden costs. The more accidents that occur in a workplace, the higher the costs — both in direct costs paid by insurance premiums and greater uninsurable indirect costs.

Typically, companies will suffer from the more numerous indirect costs that are not usually covered by any insurance. In fact, studies show that the ratio of indirect costs to direct costs varies widely, but may be as high as 20:1. The magnitude of indirect costs is inversely related to the seriousness of the injury. The less serious the injury the higher the ratio of indirect costs to direct costs.

Below are examples of direct and indirect costs of accidents in the workforce:

Direct costs (insurable)

  • workers compensation costs
  • legal insurance costs
  • vehicle insurance costs

Indirect costs (uninsurable)

  • any wages paid to injured workers for absences not covered by workers’ compensation
  • the wage costs related to time lost through work stoppage associated with the worker injury
  • the overtime costs necessitated by the injury
  • administrative time spent by supervisors, safety personnel, and clerical workers after an injury
  • training costs for a replacement worker
  • lost productivity related to work rescheduling, new employee learning curves, and accommodation of injured employees
  • clean-up, repair, and replacement costs of damaged material, machinery, and property
  • the costs of OSHA fines and any associated legal action
  • third-party liability and legal costs
  • worker pain and suffering
  • loss of good will from bad publicity that may result in loss of business

As you can see, there are many possible indirect costs associated with each accident. Every accident prevented represents potentially huge savings to the company.

This should be a foundation of justifying a fleet safety program in your workplace!


This whitepaper, developed by NETS, OSHA, and NHTSA, will help employers understand the impact of motor vehicle crashes.


Mission and Elements of the Fleet Safety Program

Like any other aspect of a workplace safety program, a Fleet Safety program should be well written, including the mission statement. Don’t neglect Fleet Safety simply because it isn’t an issue yet.

  • Mission: Your program should work to keep the driver and those with whom he/she shares the road safe. And, if necessary, the program must work to change driver attitudes, improve behavior, and increase skills to build a “be safe” culture. To do that, it’s important to educate the driver to improve attitudes. Improved attitudes will influence decision-making, behaviors, and ultimately driver performance.
  • Elements: By instructing your employees in basic safe driving practices and then rewarding safety-conscious behavior, you can help your employees and their families avoid tragedy.
Check Out: Basics of a Fleet Safety Program

Your Fleet Safety Program should at least include the following elements:

          • Written policy
          • Program administration (roles and responsibilities)
          • Driver selection, authorization, and review
          • Driver training
          • Driver incentives and recognition
          • Driver discipline
          • Drug and alcohol testing
          • Emergency equipment
          • Vehicle inspection and maintenance
          • Accident reporting and investigation
          • Recordkeeping

Getting started in establishing a World Class Fleet Safety Program

The following 10 Action Steps, originally developed by the Network of Employers for Traffic Safety (NETS), will help you improve your fleet safety performance and minimize the risk of fleet motor vehicle crashes. Following these steps helps to ensure that you hire capable drivers, only allow eligible drivers to drive on company business, train them, supervise them, and maintain company vehicles properly.

Think about developing a team to work on these steps:

  1. Develop ways senior management can demonstrate commitment & employees can get involved.
  2. Develop written fleet safety management policies and procedures.
  3. Develop and insist on the use of driver agreements.
  4. Complete Motor Vehicle Record (MVR) checks.
  5. Report crashes and make sure they are effectively investigated.
  6. Make sure vehicles are properly selected for the job, that preventive/corrective maintenance is performed, and that inspections are regularly conducted.
  7. Institute a fair and objective disciplinary action system.
  8. Recognize and reward professional performance, and offer incentives for sustained professionalism.
  9. Conduct effective safety meetings, driver training, and communications systems.
  10. Work with regulatory agencies to ensure the regulatory compliance is achieved.


Comprehensive Loss Prevention, Don’t Just be Reactive

A deposit mysteriously disappeared so instructions were added to cash handling procedures and bank reconciliations. A cashier was caught stealing. She was fired and a replacement hired after checking their background a little more thoroughly. An act of vandalism occurred so cameras were installed. Slip and fall accidents were increasing, so floors are mopped more frequently and employees advised to be more careful walking on wet floors.

The above solutions are parts of a loss prevention program developed as a piecemeal reaction to issues in retail and restaurant environments. It happens out of necessity to protect company assets, profitability, and the health and safety of employees and customers. They may provide a short-term solution, or act as a band-aid to cover-up major underlying issues.


The 4 main sources of risk that a loss prevention plan should aim to address are:

1. External Crime

Whether business owners run operations in quiet neighborhoods, out of rented units in industrial buildings or even in a corner of a crowded shopping complex, many have the wrong impression that their businesses are “too small” to become a target for fraud or sabotage. This results in operators taking unnecessarily dangerous risks in day- to- day business operations without even realizing it and sometimes paying a heavy price for this complacency. External crime elements include theft, robbery, acts of vandalism and anarchy.

2. Internal Crime

Statistics have shown that in some industries up to 80% of losses from theft are actually perpetuated by employees. Improper processes with inadequate internal checks and balances, coupled with overly trusting and empowering employees with authority, can result in systemic abuse of blind spots in a company’s business operations. This is especially the case if delegation and supervision of work is not properly managed.

3. Negligence & Ignorance

A safety supervisor can choose to ignore safety procedures when conducting high pressure testing in a fabrication yard resulting in the deaths of technicians should the equipment fail unexpectedly. An inexperienced clerk in a freight forwarding company may process paperwork for the export of controlled cargo and by doing so, directly contravene export control regimes endorsed by the country he/she is working in. Business operators themselves can also be negligent in ensuring proper systems are in place to address any possible natural disasters or by failing to establish the necessary safety procedures in their companies. Cost cutting by hiring incompetent staff who demand low salaries but do not have the necessary knowledge or experience to perform a job function properly, can easily expose the company to risk from negligence and ignorance.

4. Poorly Designed Processes

Processes within business operations are not always well managed and this can lead to severe impact on business operations, such as when proper processes are not drawn up for the handing and taking over of duties post resignation. This can lead to a sudden loss of critical technical and intrinsic knowledge.


Any good loss prevention plan must be dynamic and comprehensive enough to cover all aspects of business operations, while always being able to respond to changing threats and new risks that may present themselves. A well-developed plan helps prevent damage to business continuity by ensuring that the business operation is reasonably secured against various kinds of threats.

Business operators must develop a strong loss prevention plan in order to ensure that business operations are secured against crime, protected from vulnerability and that employees/business operations in general are not exposed to undue risk during day to day activities.

Creating checks and balances through processes meant to protect business operations from risk can often add a layer of inconvenience to business operations.

Hence, a loss prevention plan must take productivity into account and strike a clean balance between business efficiency and vulnerability.

Policies and Procedures – Well written and comprehensive policies and procedures are the foundation of successful businesses. It provides the”way of work”, direction, and accountability for everyone in the organization.


Hiring – A productive and compliant workforce begins with a culture that has established clear expectations of performance that align with common goals and objectives. Hiring new workers is about finding the right fit for the right position. Pre-employment screening, personality assessments, testing proficiencies, and other tools to identify the right employee may be included in a comprehensive loss prevention program.


Training – After the right person is hired they need to be trained on basics such as time and attendance procedures and the essential skills needed to perform their job effectively and efficiently. They need to know policies and procedures, have access to a copy, and acknowledge in writing that they understand the company’s expectations of them.


Cash Management If the employee handles cash and/or deposits, they should demonstrate accuracy in counting cash, proficiency in operating the cash register, and responsibility in fully meeting accountability expectations.


Point of Sale (POS) Procedures – Cashiers must follow correct transaction procedures in handling cash and cashless cards. Acceptable limits must be established in cash variances and cash components such as no sales, voids, refunds, price reductions, employee meals, and promotions. Managers and supervisors must understand how to utilize relevant reports from the POS system to identify training and theft issues. Proper disciplinary action can then be applied.


Food Prep and Handling – Proper training on prepping and handling food is extremely important in serving quality product. It also serves to reduce raw and completed waste and plays an important role in maintaining proper inventory control and effective food orders.


Merchandise Handling – Receiving merchandise, prepping it for transfer to the sales floor, and reconfiguring displays requires delicate handling. Accuracy in pricing and transmitting price reductions is extremely important.


Inventory Control – Proper analysis of product sales, stock rotation of first in – first out, and establishing inventory counts of key items are essential elements in effective inventory control procedures. Loss prevention measures include documenting merchandise taken out of stock, food waste, securing and controlling access to the back door, and training all employees on issues affecting poor food cost and inventory shrinkage.


Fraud and Robbery Prevention – External fraud and robbery are serious threats not only to the profitability of the company, but the health and safety of employees and customers. Employees trained to recognize suspicious behavior and transactions and respond appropriately can minimize fraud activity. They must also be trained in the procedures designed to prevent robberies and how to respond appropriately during and after to minimize the risk of being injured or killed.


Safety – There are many hazards that jeopardize the health and safety of employees and customers. Wet and greasy floors contribute to slip and fall accidents. Employees not wearing Personal Protection Equipment (PPE) are susceptible to serious burns, cuts, falls and other injuries that affect productivity and profitability. Improper training may contribute to fires, poisoning, electrical shocks, limbs caught in equipment, even death.


Audits – A systematic audit program is a critical component of a comprehensive program. It verifies that company policies, procedures, and processes are routinely followed and checks and balances are in place. When non-compliance to the rules is determined to be an issue, action plans for correction and follow-up keep activities focused on achieving goals and objectives and deter counterproductive behavior.


Progressive Discipline – Effective progressive discipline policies identify and address employee misconduct, poor performance, unacceptable behavior, and violations of policy. The seriousness or repetition of a behavior or violation will determine the level of discipline ranging from verbal warnings to termination. A consistent and fairly applied progressive discipline program enhances performance and productivity.


Security & Safety Equipment – All of the components of a comprehensive loss prevention program above can be applied with no or little cost. The program can be effectively supplemented with equipment that enhances profit protection and crime prevention. The financial investment will have excellent returns. Data mining and exception reporting software produce valuable information in employee productivity and performance. The software can be integrated with digital cameras to highlight suspicious activity and attach associated video. SMART safes protect funds, greatly reduce labor hours in counting cash and preparing deposits, and limit exposure to cash thefts and robbery. Floor cleaning machines provide greater cleaning power reducing the slipperiness of tile floors.


Addressing security and safety issues only when they surface is similar to the old Whac-A-Mole arcade game. As the mole appears it is hammered down, only for it to pop up somewhere else and again is hammered down. The game accelerates faster and faster until the player cannot catch up. A comprehensive loss prevention plan is the coordination of programs, techniques, training, and equipment to prevent profit draining and crime activity from occurring, and providing the proper reaction to mitigate them if they do occur. You’re ready for that little mole, if and when it appears. And when you whack it, it’s not likely to reappear saving you time and energy.

A loss prevention plan once implemented must be reviewed on a regular basis in order to maintain its effectiveness.

Bloodborne Pathogen Exposure Control Plan

An employer exposure control plan (ECP) is a requirement of 29 CFR 1910.1030(c) of the Bloodborne Pathogens Standard established by the Occupational Safety and Health Administration (OSHA). The purpose of the ECP is to establish procedures to eliminate or minimize employee exposure to bloodborne pathogens.

Bloodborne Pathogen Policy

Notice in the sample below, the policy is specific to a facility, not the business. This is because a business with multiple work-sites must have a separate Exposure Control Program for each site.

The policy establishes the required contents of the ECP.

Sample Policy

The (Your facility name) is committed to providing a safe and healthful work environment for our entire staff. In pursuit of this goal, the following exposure control plan (ECP) is provided to eliminate or minimize occupational exposure to bloodborne pathogens in accordance with OSHA standard 29 CFR 1910.1030, “Occupational Exposure to Bloodborne Pathogens.”

The ECP is a key document to assist our organization in implementing and ensuring compliance with the standard, thereby protecting our employees. This ECP includes:

  • determination of employee exposure
  • implementation of various methods of exposure control, including:
    • universal precautions
    • engineering and work practice controls
    • personal protective equipment
    • housekeeping
  • hepatitis B vaccination
  • post-exposure evaluation and follow-up
  • communication of hazards to employees and training
  • recordkeeping
  • procedures for evaluating circumstances surrounding exposure incidents

Implementation methods for these elements of the standard are discussed in the subsequent pages of this ECP.

For a Bloodborne Pathogen Program, check out what the EHS Center has to offer here

Program Administration

The program administration section of the Exposure Control Plan (ECP) is very important. Within this section of the ECP, the people and/or departments responsible for the various administrative functions are identified.

The program administrative section determines who will:

  • implement the ECP
  • maintain, review, and update the ECP
  • provide PPE and all necessary equipment or materials
  • ensure all medical actions required are performed and OSHA records are maintained
  • ensure training and document the training
  • make available the ECP to employees, OSHA and/or NIOSH representatives


Sample Program Administration

  • (Name of responsible person or department) is (are) responsible for implementation of the ECP. (Name of responsible person or department) will maintain, review, and update the ECP at least annually, and whenever necessary to include new or modified tasks and procedures. Contact location/phone number: __________.
  • Those employees who are determined to have occupational exposure to blood or other potentially infectious materials (OPIM) must comply with the procedures and work practices outlined in this ECP.
  • (Name of responsible person or department) will provide and maintain all necessary personal protective equipment (PPE), engineering controls (e.g., sharps containers), labels, and red bags as required by the standard. (Name of responsible person or department) will ensure that adequate supplies of the aforementioned equipment are available in the appropriate sizes. Contact location/phone number: __________.
  • (Name of responsible person or department) will be responsible for ensuring that all medical actions required by the standard are performed and that appropriate employee health and OSHA records are maintained. Contact location/phone number: __________.
  • (Name of responsible person or department) will be responsible for training, documentation of training, and making the written ECP available to employees, OSHA, and NIOSH representatives. Contact location/phone number: __________.
Check Out: Understanding OSHA Bloodborne Pathogens Standard

Employee Exposure Determination

One of the key elements of the Exposure Control Plan (ECP) is the employee exposure determination. This section of the plan lists all job classifications at the work-site with occupational exposure to bloodborne pathogens.

For example, in this section you might identify the job title “Housekeeper” within the department “Facility Maintenence”.

Notice that individual names are not used. Occupational exposure is classified by the job or task, not by the individual.

In addition to identifying the job classification and department, the ECP should also identify the procedures, or group of closely related tasks and procedures, in which occupational exposure may occur.

Adding to our previous example, the job title, location, and task would be identified as “Housekeeper / Facility Maintenence / Handling Regulated Waste”.

NOTE: Part-time, temporary, contract and per diem employees are covered by the bloodborne pathogens standard. The ECP should describe how the standard will be met for these employees.

Sample Employee Exposure Determination

The following is a list of all job classifications at our establishment in which all employees have occupational exposure:

Job Title Department/Location
(Example: Phlebotomists) (Clinical Lab)

Use as many lines as necessary.

The following is a list of job classifications in which some employees at our establishment have occupational exposure. Included is a list of tasks and procedures, or groups of closely related tasks and procedures, in which occupational exposure may occur for these individuals:

Job Title / Department – Location / Task – Procedure

(Example: Housekeeper / Environmental Services Handling / Regulated Waste)

Use as many lines as necessary.


What jobs are most at risk of exposure to bloodborne pathogens?

Occupations with a likely chance of occupational exposure include:

  • First aid providers
  • Teachers
  • Daycare workers
  • Housekeepers
  • Lab workers
  • Firefighters
  • Emergency Medical Technicians (EMTs) and paramedics
  • Law enforcement agents
  • Medical and dental personnel

An employer must review every job classification and make a determination of the potential occupational exposure for that position. Failure to properly identify potential occupational exposure can result in warnings or fines issued by OSHA.

If an occupational exposure does occur, it is important for you to follow the employer’s written procedures for handling medical self-care and evaluation, as well as documenting the circumstances of the exposure.



Methods of Implementation and Control

This section of the Exposure Control Plan (ECP) discusses the methods and controls the organization will use to prevent occupational exposure.

Topics included in this section of the ECP are:

  • Exposure Control Plan
  • Engineering Controls and Work Practices
  • Personal Protective Equipment (PPE)
  • Housekeeping
  • Laundry
  • Labels

Methods To Control The Risk Of Exposure

The recommended infection-control concept called “Universal Precautions” advocates everyone’s blood and body fluids be considered potentially infectious. This eliminates the difficulty in determining risk individually. Remember, although some bodily fluids have not been documented to transmit pathogens, it is sometimes impossible to tell if blood or another potentially infectious fluid is present.

PPE for Bloodborne Pathogens

Personal Protective Equipment (PPE) is specialized clothing or equipment that protects you from exposure to blood or other potentially infectious material.

Personal protective equipment is designed to keep blood and other potentially infectious material away from your skin, eyes, and mouth.

Examples of PPE include: disposable gloves, gowns, laboratory coats, protective face shields, resuscitation masks or shields, and mouth pieces. Any equipment necessary to prevent exposure to blood or other potentially infectious material is considered PPE.

Effective PPE

Effective personal protective equipment must not allow potentially infectious materials to pass through or reach your skin, eyes, mouth, or clothes under normal conditions of use.

General work clothes, such as uniforms, pants, shirts, or blouses, which are not intended to function as a protective barrier against hazards, are not considered to be PPE.

Employer responsibilities

An employer must ensure employees use appropriate personal protective equipment.

Your employer must make PPE available to you in the appropriate size and at no cost. Non-latex alternatives will also be made available to employees who have allergic sensitivity to latex. Employers must also properly clean, launder, repair, replace, or dispose of contaminated PPE as needed at no cost to the employee.

Employees should never take contaminated clothing home to be washed. This can increase the chance of accidental exposure to themselves and their family.


Sample Methods of Implementation and Control

Universal Precautions

All employees will utilize universal precautions.

Exposure Control Plan

Employees covered by the bloodborne pathogens standard receive an explanation of this ECP during their initial training session. It will also be reviewed in their annual refresher training. All employees can review this plan at any time during their work shifts by contacting (Name of responsible person or department). If requested, we will provide an employee with a copy of the ECP free of charge and within 15 days of the request.

(Name of responsible person or department) is responsible for reviewing and updating the ECP annually or more frequently if necessary to reflect any new or modified tasks and procedures that affect occupational exposure and to reflect new or revised employee positions with occupational exposure.

Engineering Controls and Work Practices

Engineering controls and work practice controls will be used to prevent or minimize exposure to bloodborne pathogens. The specific engineering controls and work practice controls used are listed below:

(For example: non-glass capillary tubes, SESIPs, needleless systems)

Sharps disposal containers are inspected and maintained or replaced by (Name of responsible person or department) every (list frequency) or whenever necessary to prevent overfilling.

This facility identifies the need for changes in engineering controls and work practices through __________ (Examples: Review of OSHA records, employee interviews, committee activities, etc.)

We evaluate new procedures and new products regularly by __________ (Describe the process, literature reviewed, supplier info, products considered)

Both front-line workers and management officials are involved in this process in the following manner: __________ (Describe employees’ involvement)

(Name of responsible person or department) is responsible for ensuring that these recommendations are implemented.

Personal Protective Equipment (PPE)

PPE is provided to our employees at no cost to them. Training in the use of the appropriate PPE for specific tasks or procedures is provided by (Name of responsible person or department).

The types of PPE available to employees are as follows: _________ (gloves, eye protection, etc.)

PPE is located (List location) and may be obtained through (Name of responsible person or department). (Specify how employees will obtain PPE and who is responsible for ensuring that PPE is available.)

All employees using PPE must observe the following precautions:

  • Wash hands immediately or as soon as feasible after removing gloves or other PPE.
  • Remove PPE after it becomes contaminated and before leaving the work area.
  • Used PPE may be disposed of in (List appropriate containers for storage, laundering, decontamination, or disposal.)
  • Wear appropriate gloves when it is reasonably anticipated that there may be hand contact with blood or OPIM, and when handling or touching contaminated items or surfaces; replace gloves if torn, punctured or contaminated, or if their ability to function as a barrier is compromised.
  • Utility gloves may be decontaminated for reuse if their integrity is not compromised; discard utility gloves if they show signs of cracking, peeling, tearing, puncturing, or deterioration.
  • Never wash or decontaminate disposable gloves for reuse.
  • Wear appropriate face and eye protection when splashes, sprays, spatters, or droplets of blood or OPIM pose a hazard to the eye, nose, or mouth.
  • Remove immediately or as soon as feasible any garment contaminated by blood or OPIM, in such a way as to avoid contact with the outer surface.

The procedure for handling used PPE is as follows: _________ (may refer to specific procedure by title or number and last date of review; include how and where to decontaminate face shields, eye protection, resuscitation equipment)


Regulated waste is placed in containers which are closable, constructed to contain all contents and prevent leakage, appropriately labeled or color-coded (see the following section “Labels”), and closed prior to removal to prevent spillage or protrusion of contents during handling.

The procedure for handling sharps disposal containers is: (may refer to specific procedure by title or number and last date of review)

The procedure for handling other regulated waste is: (may refer to specific procedure by title or number and last date of review)

Contaminated sharps are discarded immediately or as soon as possible in containers that are closable, puncture-resistant, leak proof on sides and bottoms, and appropriately labeled or color-coded. Sharps disposal containers are available at (must be easily accessible and as close as feasible to the immediate area where sharps are used).

Bins and pails (e.g., wash or emesis basins) are cleaned and decontaminated as soon as feasible after visible contamination.

Broken glassware that may be contaminated is only picked up using mechanical means, such as a brush and dustpan.


The following contaminated articles will be laundered by this company:

Laundering will be performed by (Name of responsible person or department) at (time and/or location).

The following laundering requirements must be met:

  • Handle contaminated laundry as little as possible, with minimal agitation
  • Place wet contaminated laundry in leak-proof, labeled or color-coded containers before transport. Use (specify either red bags or bags marked with the biohazard symbol) for this purpose.
  • Wear the following PPE when handling and/or sorting contaminated laundry: __________ (List appropriate PPE).


The following labeling methods are used in this facility:

Equipment to be Labeled: _________ (Label Type and Size, Color ) (specimens, contaminated laundry, etc.) (red bag, biohazard label)

(Name of responsible person or department) is responsible for ensuring that warning labels are affixed or red bags are used as required if regulated waste or contaminated equipment is brought into the facility. Employees are to notify (Name of responsible person or department) if they discover regulated waste containers, refrigerators containing blood or OPIM, contaminated equipment, etc., without proper labels.


Read: Understanding OSHA Bloodborne Pathogens Standard

Hepatitis B Vaccination

This section of the exposure control plan (ECP) establishes your organizations policy regarding hepatitis B (HBV) vaccinations.

Employers are required to provide the HBV vaccination to employess at no cost within 10 days of initial assignment.

It is important to note that “employers” includes both for-profit and non-profits organizations. Volunteers are considered employees for the purpose of the Bloodborne Pathogens standard. Also, if a school, requires students to perform tasks which exposes them to bloodborne pathogens, the school may be required to provide the HBV vaccination at no cost to the student.

The hepatitis B immunization series requires three separate injections.

The hepatitis B vaccine is very effective in protecting against the hepatitis B virus. Approximately 90 percent of people who receive the vaccine will become fully immune to the virus. It is given in a series of three shots. The entire series of shots is required to provide full immunity. The vaccine is safe with very few adverse reactions.

Typical Vaccination Schedule: The first injection can be administered at any given time. The second injection must be given at least one month after the first, and the third injection must be given six months after the first.

A licensed physician or other healthcare professional will perform or supervise the vaccinations.

Your employer does not have to offer you the vaccination series if you have previously received the complete series or have tested as immune to HBV.

You can decline the vaccination for hepatitis B after being informed of the risks and benefits.  To do this, you must sign a declination form. If you initially decline the vaccination for Hepatitis B, you can later request it from your employer at no charge.

There are currently two vaccines used to prevent hepatitis B infection in the United States. Neither vaccine contains blood products. You cannot get Hepatitis B from these vaccines.

Vaccination is encouraged unless:

  1. Documentation exists that the employee has previously received the series
  2. Antibody testing reveals that the employee is immune
  3. Medical evaluation shows that vaccination is contraindicated

Employees can decline the vaccination. If they do, the employee must sign a declination form. Employees who decline the vaccination may request and obtain the vaccination at a later date at no cost.

For the forms needed for a Hepatitus B Vaccine and Declination form, check out what the EHS Center offers here

Post-Exposure Evaluation and Follow-Up

OSHA expects employers to have a plan in place in the event an employee does have an occupational exposure.

This section of the Exposure Control Plan (ECP) must identify the person responsible for post-exposure follow-up.

Additionally, this section of the ECP must provide the post-exposure steps to be taken in the event of an occupational exposure. Remember, employees must be able to access the ECP for their personal review, even if an exposure has not occurred.

Sample Post-Exposure Evaluation and Follow-Up

Should an exposure incident occur, contact (Name of responsible person) at the following number __________.

An immediately available confidential medical evaluation and follow-up will be conducted by (name of licensed health care professional).

Following initial first aid (clean the wound, flush eyes or other mucous membrane, etc.), the following activities will be performed:

  • Document the routes of exposure and how the exposure occurred.
  • Identify and document the source individual (unless the employer can establish that identification is infeasible or prohibited by state or local law).
  • Obtain consent and make arrangements to have the source individual tested as soon as possible to determine HIV, HCV, and HBV infectivity; document that the source individual’s test results were conveyed to the employee’s health care provider.
  • If the source individual is already known to be HIV, HCV and/or HBV positive, new testing need not be performed.
  • Assure that the exposed employee is provided with the source individual’s test results and with information about applicable disclosure laws and regulations concerning the identity and infectious status of the source individual (e.g., laws protecting confidentiality).
  • After obtaining consent, collect exposed employee’s blood as soon as feasible after exposure incident, and test blood for HBV and HIV serological status
  • If the employee does not give consent for HIV serological testing during collection of blood for baseline testing, preserve the baseline blood sample for at least 90 days; if the exposed employee elects to have the baseline sample tested during this waiting period, perform testing as soon as feasible.

Administration of Post-Exposure Evaluation and Follow-Up

This section of the Exposure Control Plan (ECP) identifies the person or department responsible for ensuring the post-exposure evaluation and follow-up are performed.

After the post-exposure evaluation is completed, the employee must be provided a copy of the health care professional’s written opinion within 15 days after the evaluation is completed.

Sample Administration of Post-Exposure Evaluation and Follow-Up

(Name of responsible person or department) ensures that health care professional(s) responsible for employee’s hepatitis B vaccination and post-exposure evaluation and follow-up are given a copy of OSHA’s bloodborne pathogens standard.

(Name of responsible person or department) ensures that the health care professional evaluating an employee after an exposure incident receives the following:

  • A description of the employee’s job duties relevant to the exposure incident
  • Route(s) of exposure
  • Circumstances of exposure
  • If possible, results of the source individual’s blood test
  • Relevant employee medical records, including vaccination status

(Name of responsible person or department) provides the employee with a copy of the evaluating health care professional’s written opinion within 15 days after completion of the evaluation.


Procedures for Evaluating the Circumstances Surrounding an Exposure Incident

This section of the Exposure Control Plan (ECP) identifies who is responsible for evaluating an exposure incident. In addition, it should list what will be included as part of the evaluation process.

One important piece to this section is the recording of percutaneous injuries from contaminated sharps in a Sharps Injury Log. If your company is not required to maintain a Sharps Injury Log, then this can be excluded.

Sample Procedures for Evaluating the Circumstances Surrounding an Exposure Incident

(Name of responsible person or department) will review the circumstances of all exposure incidents to determine:

  • engineering controls in use at the time
  • work practices followed
  • a description of the device being used (including type and brand)
  • protective equipment or clothing that was used at the time of the exposure incident (gloves, eye shields, etc.)
  • location of the incident (O.R., E.R., patient room, etc.)
  • procedure being performed when the incident occurred
  • employee’s training

(Name of Responsible Person) will record all percutaneous injuries from contaminated sharps in a Sharps Injury Log.

If revisions to this ECP are necessary (Responsible person or department) will ensure that appropriate changes are made. (Changes may include an evaluation of safer devices, adding employees to the exposure determination list, etc.)

Employee Training

All employees who have been identified as having occupational exposure must receive initial and annual Bloodborne Pathogens training. Remember, you should have already identified all of the job classifications previously in your Exposure Control Plan.

Some companies put all of their employees through this training, regardless of their job classification, especially if an employee’s job classification can change. This can potentially save in training costs, by reducing the number of separate trainings that might need to be offered. For example, primary and secondary teachers are often given this training at the beginning of each school year.

Computer based training (CBT) can be used to provide this training if all of the criteria below are met. It is important to note that hands on training for personal protective equipment (PPE) will be required for bloodborne pathogens training. Employees must be able to practice putting on and taking off the PPE, as well as being instructed in it’s proper use.

Sample Employee Training

All employees who have occupational exposure to bloodborne pathogens receive initial and annual training conducted by (Name of responsible person or department). (Attach a brief description of their qualifications.)

All employees who have occupational exposure to bloodborne pathogens receive training on the epidemiology, symptoms, and transmission of bloodborne pathogen diseases. In addition, the training program covers, at a minimum, the following elements:

  • a copy and explanation of the OSHA bloodborne pathogen standard
  • an explanation of our ECP and how to obtain a copy
  • an explanation of methods to recognize tasks and other activities that may involve exposure to blood and OPIM, including what constitutes an exposure incident
  • an explanation of the use and limitations of engineering controls, work practices, and PPE
  • an explanation of the types, uses, location, removal, handling, decontamination, and disposal of PPE
  • an explanation of the basis for PPE selection
  • information on the hepatitis B vaccine, including information on its efficacy, safety, method of administration, the benefits of being vaccinated, and that the vaccine will be offered free of charge
  • information on the appropriate actions to take and persons to contact in an emergency involving blood or OPIM
  • an explanation of the procedure to follow if an exposure incident occurs, including the method of reporting the incident and the medical follow-up that will be made available
  • information on the post-exposure evaluation and follow-up that the employer is required to provide for the employee following an exposure incident
  • an explanation of the signs and labels and/or color coding required by the standard and used at this facility
  • an opportunity for interactive questions and answers with the person conducting the training session

Training materials for this facility are available at (name location).


This section of the Exposure Control Plan (ECP) details what training records must be maintained in relation to:

  • Training
  • Medical Records
  • OSHA Recordkeeping
  • Sharps Injury Log

These documents must be maintained for at least three (3) years.

Additionally, an employee or their authorized representative may request a copy of the employee’s exposure and medical records.

Sample Recordkeeping

Training Records

Training records are completed for each employee upon completion of training. These documents will be kept for at least three years at (Location of records).

The training records include:

  • the dates of the training sessions
  • the contents or a summary of the training sessions
  • the names and qualifications of persons conducting the training
  • the names and job titles of all persons attending the training sessions

Employee training records are provided upon request to the employee or the employee’s authorized representative within 15 working days. Such requests should be addressed to (Name of responsible person or department).

Medical Records

Medical records are maintained for each employee with occupational exposure in accordance with 29 CFR 1910.1020, “Access to Employee Exposure and Medical Records.”

(Name of responsible person or department) is responsible for maintenance of the required medical records. These confidential records are kept in (List location) for at least the duration of employment plus 30 years.

Employee medical records are provided upon request of the employee or to anyone having written consent of the employee within 15 working days. Such requests should be sent to (Name of responsible person or department and address).

OSHA Recordkeeping

An exposure incident is evaluated to determine if the case meets OSHA’s Recordkeeping Requirements (29 CFR 1904). This determination and the recording activities are done by (Name of responsible person or department).

Sharps Injury Log

In addition to the 1904 Recordkeeping Requirements, all percutaneous injuries from contaminated sharps are also recorded in a Sharps Injury Log. All incidences must include at least:

  • Date of the injury
  • Type and brand of the device involved (syringe, suture needle)
  • Department or work area where the incident occurred
  • Explanation of how the incident occurred.

This log is reviewed as part of the annual program evaluation and maintained for at least five years following the end of the calendar year covered. If a copy is requested by anyone, it must have any personal identifiers removed from the report.