Kevin Ian Schmidt

Understanding OSHA Bloodborne Pathogens Standard

Bloodborne pathogens are infectious microorganisms in human blood that can cause disease in humans. These pathogens include, but are not limited to, hepatitis B (HBV), hepatitis C (HCV) and human immunodeficiency virus (HIV).

Workers in many occupations, including first responders, housekeeping personnel in some industries, nurses and other healthcare personnel, all may be at risk for exposure to bloodborne pathogens.

Bloodborne pathogens are capable of causing serious illness and death. The most common illnesses caused by bloodborne pathogens are hepatitis B (HBV), hepatitis C (HCV, and acquired immunodeficiency syndrome (AIDS) from HIV.

Check Out: BloodBorne Pathogen Exposure Control Plan

Who is covered by OSHA’s Bloodborne Pathogens Standard?

The standard applies to all employees who have occupational exposure to blood or other potentially infectious materials (OPIM).

Employees who provide first aid as part of their job are required to have training on occupational exposure.

  • Occupational exposure is defined as “reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or OPIM that may result from the performance of the employee’s duties.”
  • Blood is defined as “human blood, human blood components, and products made from human blood.”
  • Other potentially infectious materials (OPIM) means:
    1. The following human body fluids: semen, vaginal secretions, cerebrospinal fluid, synovial fluid, pleural fluid, pericardial fluid, peritoneal fluid, amniotic fluid, saliva in dental procedures, any body fluid that is visibly contaminated with blood, and all body fluids in situations where it is difficult or impossible to differentiate between body fluids;
    2. Any unfixed tissue or organ (other than intact skin) from a human (living or dead); and
    3. HIV-containing cell or tissue cultures, organ cultures, and HIV- or HBV-containing culture medium or other solutions; and blood, organs, or other tissues from experimental animals infected with HIV or HBV.

You can find more information on recognizing workplace hazards associated with bloodborne pathogens on OSHA’s Hazard Recognition Page.

What is the purpose of OSHA’s Bloodborne Pathogens standard?

The purpose of the standard is to minimize or eliminate occupational exposure to disease-carrying microorganisms or “pathogens” that can be found in human blood and body fluids.

Who must be trained under OSHA’s Bloodborne Pathogens standard?

OSHA has mandated annual training is required for all employees with potential occupational exposure. This means if there is a reasonable possibility an employee might be exposed to blood or other potentially infectious materials (OPIM),other potentially infectious bodily fluids, they must receive training to minimize or eliminate their risk to potential exposure.

OSHA has determined employers can minimize or even eliminate occupational bloodborne hazards by developing and enforcing a combination of exposure control strategies which work for all bloodborne diseases. It is not enough for an employer to provide bloodborne pathogens training; they must also have a formal exposure control plan documented and implemented.

TRAINING IS NOT ENOUGH; an employer must implement a Formal Exposure Control Plan, which can be found at the EHS Center.

What are the primary bloodborne pathogens?

The primary bloodborne pathogens are:

  • Hepatitis B Virus (HBV)
  • Hepatitis C Virus (HCV)
  • Human immunodeficiency virus (HIV)

Other commonly recognized pathogens transmitted by body fluids include:

  • West Nile Virus
  • Malaria
  • Syphilis


Hepatitis B Virus (HBV)

The hepatitis B virus (HBV) is one of the primary causes of Hepatitis, an infection which causes inflammation of the liver. Complications of Hepatitis include cirrhosis (scarring) of the liver, liver cancer, and liver failure. There is no known cure for the hepatitis B virus. In the United States, approximately 15 to 25 percent of people infected with HBV will die because of the illness.

According to the Hepatitis B Foundation, thousands of people in the United States and 600,000 people worldwide die from hepatitis B-related liver disease annually.

The Center for Disease Control (CDC) reported 2,953 confirmed acute cases of hepatitis B in 2014. The CDC estimates 19,200 people were infected with the hepatitis B virus the same year.

Hepatitis B can be either acute or chronic:

  • Acute hepatitis B virus infection is a short-term illness that occurs within the first 6 months after someone is exposed to the Hepatitis B virus. Acute infection can, but does not always, lead to chronic infection.
  • Chronic hepatitis B virus infection is a long-term illness that occurs when the Hepatitis B virus remains in a person’s body. Chronic Hepatitis B is a serious disease that can result in long-term health problems, and even death.

An exposure that might place a worker at risk for HBV, HCV, or HIV infection is defined as:

  1. A percutaneous injury (e.g., a needlestick or cut with a sharp object); or
  2. Contact of mucous membrane or nonintact skin (e.g., exposed skin that is chapped, abraded, or afflicted with dermatitis) with blood, tissue, or other body fluids that are potentially infectious.
  3. Indirect exposure from contaminated objects is a risk because hepatitis B virus can remain infectious on environmental surfaces for up to a week (7 days) in the form of dried blood.

This means you must always treat blood, wet or dry, as infectious!

A vaccination to prevent Hepatitis B virus infection is available. The Hepatitis B vaccine series is a sequence of three shots, typically given one month apart, that stimulate a person’s natural immune system to protect against the virus. After the vaccine is given, the body makes antibodies to protect a person against the virus. Antibodies are specialized proteins found in the blood that produce an immune response to a virus invading the body. These antibodies are stored in the body to guard against future infections. They will fight off an infection if a person is exposed to the Hepatitis B virus in the future.

Hepatitis C Virus (HCV)

The hepatitis C virus (HCV) is also a significant cause of severe liver damage and death.

Hepatitis C kills more Americans than any other infectious disease. Deaths associated with hepatitis C reached 18,153 in 2016, according to surveillance data released by the Centers for Disease Control and Prevention (CDC).

About 3.5 million Americans are currently living with hepatitis C and roughly half are unaware of their infection. Approximately 1 to 5% of people infected with hepatitis C virus die as a result of the long-term damage caused to the liver and body.

Approximately 70%-80% of people with acute hepatitis C do not have any symptoms. Some people, however, can have mild to severe symptoms soon after being infected, including:

  • fever
  • fatigue
  • loss of appetite
  • nausea
  • vomiting
  • abdominal pain
  • dark urine
  • grey-colored bowel movements
  • joint pain
  • jaundice (yellow color in the skin or eyes)

Click here to view the CDC fact sheet for Hepatitis C.

If symptoms do occur, the average incubation period is 45 days after exposure, but this can range from 14 to 180 days.

Many people infected with the hepatitis C virus do not develop symptoms.

Hepatitis C virus-infected individuals are infectious to other people, whether they show symptoms or not. Interestingly, Hepatitis C virus is strictly a human disease. It is not known to cause disease in any animals.

Blood testing for hepatitis C virus was not available until 1992. As a result, blood donation agencies did not screen for hepatitis C virus. Many hepatitis C virus infections occurred as a result of receiving blood products from infected individuals. Today, testing for hepatitis C is common place and should occur after any exposure to potential bloodborne pathogens.

There is no vaccine for Hepatitis C.


According to the CDC, approximately 15% to 25% of people infected with acute Hepatitis C will naturally be able to clear the infection from their body without treatment.

There are several medications available to treat chronic hepatitis C, including newer, more effective drugs with fewer side effects.

Around the World

According to the World Health Organization (WHO), 1.75 million people are infected with the hepatitis C virus each year. Approximately 71 million people are chronically infected and at risk of developing liver cirrhosis and/or liver cancer. About 400,000 people worldwide die from hepatitis C-related liver diseases each year.

Decontamination for HCV

Any blood spills – including dried blood, which can still be infectious – should be cleaned using a 10% dilution (1 part household bleach to 9 parts water). Gloves should always be worn when cleaning up blood spills.

Human Immunodeficiency Virus (HIV)

The Human immunodeficiency virus (HIV) is the virus responsible for causing acquired immunodeficiency syndrome (AIDS). The HIV virus was originally identified on December 1st, 1981.

Statistics on HIV
  • 38,500 new cases of HIV/AIDS in adults, adolescents, and children were diagnosed in 2015.
  • As of 2015, approximately 1.1 million people are living with HIV. The CDC estimates 15% of people living with HIV do not know they are infected.
  • As of December 31, 2013, 58 confirmed occupational transmissions of HIV and 150 possible transmissions had been reported in the United States.
  • As of 2016, there are about 36.7 million people living with HIV around the world, with only 53% receiving treatment.
  • In 2016, about one million people died from AIDS-related illnesses around the world.

The Human immunodeficiency virus attacks and suppresses the immune system, reducing a person’s ability to fight infection. The virus specifically targets the cells crucial for fighting infection from pathogens. This allows diseases and infections to progress without resistance.

Within a few weeks of being infected with HIV, some people develop flu-like symptoms that last for a week or two, but others have no symptoms at all. People living with HIV may appear and feel healthy for several years. However, even if they feel healthy, HIV is still affecting their bodies. Untreated early HIV infection is also associated with many diseases including cardiovascular disease, kidney disease, liver disease, and cancer.

It can take many years before an HIV-infected person displays symptoms of the disease.

Symptoms include:

  • enlarged lymph nodes
  • fatigue
  • frequent fevers
  • persistent or frequent yeast infections of the mouth or vagina
  • persistent or frequent skin rashes
  • short-term memory loss
  • weight loss
  • enlarged liver and spleen

Presently, there is no known cure for HIV. Treatment for HIV is called antiretroviral therapy or ART. If people with HIV take ART as prescribed, their viral load (amount of HIV in their blood) can become undetectable. If it stays undetectable, they can live long, healthy lives. Today, someone diagnosed with HIV and treated before the disease is far advanced can live nearly as long as someone who does not have HIV.

HIV cannot reproduce outside the human body. It is not spread by:

  • air or water
  • insects, including mosquitoes: studies conducted by CDC researchers and others have shown no evidence of HIV transmission from insects
  • saliva, tears, or sweat: there is no documented case of HIV being transmitted by spitting
  • casual contact like shaking hands or sharing dishes
  • closed-mouth or “social” kissing

All reported cases suggesting new or potentially unknown routes of transmission are thoroughly investigated by state and local health departments with assistance, guidance, and laboratory support from the CDC.

Disease Comparison

Of the three major bloodborne pathogens, hepatitis B virus is the most contagious. Approximately 33% of individuals exposed to hepatitis B virus will become infected. Of those individuals exposed to hepatitis C virus, only about 2% will become infected. Comparatively, human immunodeficiency virus is much less contagious than either form of hepatitis. About 0.33%, or 1 in 300, people exposed to HIV will become infected with the virus. Despite these statistics, every exposure has the potential to transmit bloodborne pathogens and must be considered significant.

Transmitting Bloodborne Pathogens

Fluids that Spread Bloodborne Pathogens

Non-occupational bloodborne pathogens are most commonly transmitted through:

  • sexual contact; or
  • sharing hypodermic needles.

Occupational bloodborne pathogens are most commonly transmitted through:

  • puncture wounds from a sharp or contaminated object, such as broken glass; or
  • from a splash of blood to the mucous membranes of the eyes, nose, or mouth.


The transmission of bloodborne pathogens from one person to another occurs through the transfer of infected body fluids.

Common body fluids which can transmit pathogens include:

  • blood
  • cerebral spinal fluid
  • semen
  • vaginal secretions

Semen and vaginal secretions can transmit bloodborne pathogens, but only during sexual contact.

Wearing disposable gloves can help protect you from accidental exposure to bloodborne pathogens.

Fluids that Do Not Spread Bloodborne Pathogens

Some body fluids have no documented risk of transmitting pathogens, including:

  • sweat
  • saliva
  • urine
  • feces

Although the risk of contracting a pathogen from these bodily fluids might be low, you may not always be able to tell which fluids you are handling, or whether injury has mixed them with blood.

For example, a severe abdominal injury could cause blood to be present in urine or feces. Therefore, it is best to protect yourself from ALL bodily fluids.

Establishing a Safety Committee

An effective safety committee may not only help prevent employees’ from getting hurt or killed on the job, it may help decrease future direct and indirect accident costs. An effective safety committee is a profit center, not a cost center for the company.

According to the U.S. Bureau of Labor Statistics (BLS), nearly 3 million non-fatal workplace injuries and illnesses were reported by private industry employers in 2016. According to the Liberty Mutual Workplace Safety Index, U.S. businesses spend more than one billion dollars a week on serious, nonfatal workplace injuries.

What do these statistics mean to you? Effective “profit center” safety committees have the potential to save not only lives and limbs, but lots of money. Many thousands of dollars each year can be saved in each company every time a safety committee uncovers and helps the employer eliminate hazardous conditions or unsafe work practices.

Every dollar invested in proactive safety, including safety committee activities, may return hundreds back. You’ve got to convince management that an effective safety committee not only saves lives, but saves money too.

To help the safety committee function better, each member must understand this basic principle:

What we do depends on who we think we are.

For example, if safety committee members:

  • believe they are consultants, they will do and say things that send a message they can be trusted. Employees will seek their help and appreciate their work.
  • believe they are cops, they will do and say things in a manner that is likely to result in mistrust. And, as we know, an effective safety culture can not exist in a climate of mistrust.

Benefits of a Safety Committee

  • The safety committee performs the role of a internal consultant to the employer. If your employer hired an external consultant it would cost thousands of dollars for the same service the safety committee can provide in-house.
  • The safety committee acts as a forum for management and labor to communicate safety related concerns. The benefits from improved communications may be hard to quantify, but they may be substantial.
  • Every hazard the safety committee identifies and is directly involved in eliminating results in significant savings in potential accident costs. We’ll talk more about this later.
  • The safety committee can serve as a valuable problem solving group that addresses workplace conditions, morale and quality. By developing solutions, the safety committee improves the company’s competitive advantage.
  • The safety committee is an excellent opportunity for employees to improve their professional skills in communications, human relations, problem solving, meeting management, and analysis. Since supervisors and managers should be informed about occupational safety and health, the safety committee is a natural “school” of preparation for future company managers. In fact, some companies even make it a prerequisite.

The Safety Committee Vision Statement

To better understand and convey the role of your safety committee as an internal consultant team providing expert advice and assistance, think about creating a “vision statement.” The vision statement describes who you are. A good vision statement will help you determine what to do and make it more likely that you’ll realize that vision.

A committee with an appropriate vision is more likely to do the following to achieve their vision:

  • survey and interview employees to find out what they are thinking and feeling;
  • observe employees to analyze behaviors;
  • inspect the workplace to uncover hazardous conditions;
  • audit safety programs;
  • uncover the surface and root causes of safety problems;
  • develop and submit written recommendations;
  • monitor the progress of corrective actions and system improvements; and
  • evaluate the long-term quality of the safety culture.

Sample Vision Statement: “The safety committee helps management lead in creating a world-class safety culture through educating employees and consulting with management.”

The Safety Committee Mission Statement

A safety committee should write a mission statement that explains what they do to support their vision. The purpose of the safety committee might be viewed as its mission and describes the activities above to support its assigned role.

Sample Mission Statement: “It is the mission of the Safety Committee of XYZ Company to promote a safe working environment for all employees by assisting in the overall effort to minimize the frequency of accidents, and to identify corrective measures needed to eliminate or control recognized safety hazards.”

It is also good for your safety committee to have a slogan, something they can push out in their internal marketing efforts to raise awareness around safety. Check out this post on safety committee slogans.

As a safety committee member, you perform multiple roles. Let’s see how this affects your responsibilities:

  • Safety committee member: When performing the role of a safety committee member you are basically performing the role of an internal consultant:
    • Warn employees, but do not report “names” to the supervisor.
    • Report unsafe behaviors to the committee chairperson so the safety committee can discuss how to fix the surface and root causes.
    • Help managers and supervisors gain the knowledge, skills, and abilities (KSAs) to better enforce, supervise, and manage safety by giving them useful information.
    • Listen to employee concerns and suggestions about safety and give that information to the safety committee.
    • Educate and assist employees, but do not try to enforce safety rules: that’s a line responsibility.
  • Line employee: When performing the role of a line employee, you have a responsibility to warn the employee, but again, you’re not a cop. Report the behavior to your safety committee member, and if you are comfortable with it, to your supervisor without naming names.
  • Supervisor/Manager: When performing the role of supervisor or manager, you are the agent of the employer and are legally the “cop” who should enforce safety.
    • If you catch someone misbehaving and you have properly trained them, they have the proper resources, time, support, etc., you’re probably justified in disciplining the employee.
    • Address behaviors with everyone in training and safety meetings. It resets employee accountability when the supervisor tells all employees they are not allowed to engage in a particular unsafe behavior.

Safety Committee Written Policy

It’s important to make sure the safety committee has a written policy statement to guide its actions.

The policy statement should include:

  • the role and purpose(s) of the safety committee;
  • reasons for establishing the safety committee;
  • the need for management and employee participation;
  • the need for support by all departments;
  • responsibilities of the committee; and
  • duties of committee members.

What kind of structure should the safety committee take? Typically, the committee will have a chairperson (some will also have a co-chair), a recorder, and of course a number of members. You don’t need a complicated bureaucratic structure.

Duties of the Chairperson

The chairperson’s job is, of course, one of the most important on the committee. He or she is the key coordinator ensuring the safety committee operates effectively. Below are some of the very important responsibilities of the chairperson.

  • prepare an agenda for meetings
  • arrange for meeting room
  • notify members of meeting dates/times
  • distribute agenda
  • delegate responsibilities
  • preside and conduct the meeting
  • enforce committee ground rules
  • communicate with the employer
  • report the status of recommendations

Duties of the Safety Committee Recorder

Let’s not forget another very important responsibility: that of the recorder or secretary. This person assists the chairperson in making sure all communications are accurately recorded and distributed to committee members and others. Some duties of the recorder may include:

  • assisting the chairperson with agenda;
  • recording minutes of the meeting;
  • distributing and posting the minutes; and
  • assuming the chairperson’s duties if necessary.

Duties of the Safety Committee Member

For the safety committee to operate most effectively, everyone on the committee needs to be involved in some way. Safety committee members should do more than just report safety concerns from their departments. Below are some ideas for members.

  • Receive suggestions, concerns, reports from employees.
  • Report employee suggestions, concerns, reports to committee.
  • Report back to employees on their suggestions, concerns, reports.
  • Attend all safety committee meetings.
  • Receive training on safety and health subjects.
  • Review injury and illness reports.
  • Monitor safety and health programs and system.
  • Set example by taking action.
  • Conduct safety inspections.
  • Make recommendations for corrective action.
  • Assist in communicating committee activities to all employees.

Safety Committee Members

If one of the purposes of the safety committee is to bring management and labor together in a cooperative effort to improve the safety and health of workers, it just makes business sense to include representatives from management ranks as well as the work floor.

Management and labor can sit together and discuss their unique and common concerns regarding safety. The safety committee becomes a forum both management and labor may use, to ensure mutually acceptable solutions to problems can be reached.

It’s important the safety committee not be dominated by management in general, or any one individual, be it the safety director, chairperson, or member. To make sure this does not happen, establish ground rules, and techniques for decision-making that promotes group consensus.

Management representatives and the chairperson will be the primary conduits of communications between the safety committee and the employer. Committee members are the primary communicators with employees. It’s very important communication occurs in both directions.

The Safety Committee’s Purpose

Armed with insight into the role of the safety committee, let’s take a look at what the committee’s purpose and function might be. We’ll start by looking at the purpose of the safety committee. A quick review of our friendly dictionary once again defines “purpose” as “a desired or intended result or effect.”

For safety committees to be successful in fulfilling their role, they need to understand their purpose and how to go about achieving intended outcomes. If the safety committee does not understand it’s purpose, it may actually function to produce unintended outcomes.

Safety committees are created and developed to fulfill the following purposes:

  • help to protect the employer by providing useful information;
  • help to protect the employee by responding to safety concerns;
  • bring labor and management together in a cooperative way to solve problems;
  • help the employer educate and motivate all employees about the importance of safety; and
  • help the employer educate and motivate all supervisors and managers to identify hazards and take corrective action.

All these purpose statements emphasize the safety committee’s responsibility to help the employer do (manage) safety, not to do safety for the employer. This important idea is why we encourage safety committees to think of themselves as internal consultant groups, but not as safety “cop squads.”

Enforcing Safety Rules is Not the Safety Committee’s Job

Remember, writing “tickets” for violating safety rules can be especially disastrous to the success of the safety committee’s effectiveness: Don’t do it. Enforcing safety is considered managing safety and is a line responsibility from the CEO down through first line supervisor.


The “Function” of the Safety Committee

Purpose and function are related terms, but differ significantly in meaning. “Function” is: Something closely related to another thing and dependent on it for its existence, value, or significance. This definition implies that “function” is dependent on the “purpose” of the safety committee.

Whereas a purpose statement describes the intended result or effect of a safety committee activity, “function” describes the actual unintended result or effect. The actual outcome depends on the success of the attempt to carry out the intended purpose. If the safety committee does not effectively carry out its intended purpose, it may unintentionally function to hurt the company’s safety and health effort.

The safety committee’s function is dependent upon the effectiveness of a group to follow through with its stated purpose. The safety committee may have the best intentions, but if it cannot follow through effectively with its plans, it may actually function to harm a safety program or activity rather than help it.

Without education and training, safety committee members may not have the basic knowledge, skills, and abilities (SKAs) to perform their responsibilities. Given proper education and training, the safety committee is more likely to function to carry out its intended purpose.

For instance, the safety committee may intend to increase interest in safety by implementing a safety incentive program, but if its members do not have the SKAs to accomplish this task, they may unintentionally develop a totally reactive incentive program that results in dismal failure.

Emergency Response Plan Best Practices

An emergency response plan (ERP) or also called an Emergency Action Plan (EAP) is required by OSHA, but to be truly effective it needs to account for site specific hazards.

OSHA has minimal requirements for what to include in a basic emergency response plan; learn more here. For optimal workplace safety, there are emergency response plan best practices you should consider while drafting your plan.

Set Specific Evacuation Routes and Exits

OSHA Publication 3088 “How to Plan for Workplace Emergencies and Evacuations” states that at a minimum, your emergency action plan must include emergency escape procedures and route assignments, such as floor plans, workplace evacuation maps, and safe or refuge areas.

Most employers create maps from floor diagrams with arrows that designate the exit route assignments. These maps should include locations of exits, assembly points and equipment (such as fire extinguishers, first aid kits, spill kits) that may be needed in an emergency. Exit routes should be clearly marked and well lit, wide enough to accommodate the number of evacuating personnel, unobstructed and clear of debris at all times, and unlikely to expose evacuating personnel to additional hazards.

OSHA says that when preparing drawings that show evacuation routes and exits, you need to post them prominently for all employees to see.

Here are some important requirements to consider:

  • Make exit route design permanent.
  • Ensure the number of exit routes is adequate based on the number of employees, the size of the building, its occupancy, and the arrangement of the workplace.
  • Separate an exit route from other workplace areas with materials that have the proper fire resistance-rating for the number of stories the route connects.
  • Ensure exit routes meet width and height requirements. The width of exit routes must be sufficient to accommodate the maximum permitted occupant load of each floor served by the exit route.
  • Ensure doors used to access exit routes have side hinges and swing in the direction of travel (depending on occupancy and hazard areas).
  • Design exit routes which lead to an outside area with enough space for all occupants.
  • An outdoor exit route is permitted, but may have additional site-specific requirements.
  • Maintain the fire-retardant properties of paints and solutions that are used in exit routes.
  • Ensure required exit routes and fire protections are available and maintained, especially during repairs and alterations.
  • Ensure employee alarm systems are installed, operable, and in compliance with 29 CFR 1910.165 (Note: See Section I.A.5.).
  • Direct employees through exit routes using clearly visible signs. These signs must meet the required letter height and illumination specifications.
  • When openings could be mistaken for an exit, post appropriate signs stating “NOT AN EXIT.”
  • Arrange exit routes so employees are not exposed to the dangers of high hazard areas.
  • Exit routes must be free and unobstructed. Prevent obstructions, such as decorations, furnishings, locked doorways, and dead-ends within exit routes.
Check Out: Emergency Exits – OSHA Standards

General Training Responsibilities for an Emergency Response Plan

Educate your employees about the types of emergencies that may occur and train them in the proper course of action. The size of your workplace and workforce, processes used, materials handled, and the availability of onsite or outside resources will determine your training requirements.

  • Make sure all employees understand the function and elements of your emergency action plan, including types of potential emergencies, reporting procedures, alarm systems, and evacuation plans.
  • For those employees that are assigned to perform the task, make sure they are trained on emergency shutdown procedures.
  • Discuss any special hazards you may have onsite such as flammable materials, toxic chemicals, radioactive sources, or water-reactive substances.
  • Inform employees of the fire hazards to which they are exposed to and review with each employee those parts of the fire prevention plan necessary for self-protection.

When drafting your emergency action plan, you may wish to select a responsible individual, or more depending upon size, to lead and coordinate your emergency plan and evacuation. It is critical that employees know who the coordinator is and understand that person has the authority to make decisions during emergencies.

Designate Evacuation Coordinator(s)

Emergency response coordinators are responsible for making decisions during emergencies. To do this well, they need to be properly trained and supported by management. Inherent leadership skills help in this position, but even the best leaders may still need to be taught skills such as coordinating response efforts with outside agencies and performing risk assessments.


The coordinator(s) should be responsible for the following:

  • Assessing the situation to determine whether an emergency exists requiring activation of your emergency procedures;
  • Supervising all efforts in the area, including evacuating personnel;
  • Coordinating outside emergency services, such as medical aid and local fire departments, and ensuring that they are available and notified when necessary; and
  • Directing the shutdown of plant operations when required.

You also may find it beneficial to coordinate the action plan with other employers when several employers share the worksite, although OSHA standards do not specifically require this.

Emergency evacuation coordinators also need opportunities to practice these skills during response drills and exercises.

Assisting People During Evacuations

Employees designated to assist in emergencies should be made aware of employees with special needs (who may require extra assistance during an evacuation), how to use the buddy system, and any hazardous areas to avoid during an emergency evacuation. If there are any employees with special needs at your worksite it will be important to be aware of their needs once evacuated. You may want to consider evacuating all special needs employees to the same location if possible. At the very least consider whether the designated evacuation area is suitable to meet the needs of any special needs employees while an emergency is being addressed.

Accounting for all Employees

Accounting for all employees following an evacuation is critical. Confusion in the assembly areas can lead to delays in rescuing anyone trapped in the building, or unnecessary and dangerous search-and-rescue operations. To ensure the fastest, most accurate accounting of your employees, consider taking a head count after the evacuation. The names and last known locations of anyone not accounted for should be passed on to the official in charge.

Accounting for Visitors

Some employers have all visitors and contractors sign in when entering the workplace. The hosts and/or area wardens, if established, are often tasked with assisting these individuals evacuate safely.

Check Out: Emergency Action Plan Checklist

Update the EAP Regularly

Operations and personnel change frequently, and an outdated plan will be of little value or use in an emergency. You should review and evaluate the effectiveness the contents of your plan regularly. Update the EAP whenever:

  • employee emergency actions or responsibilities change,
  • when there is a change in the layout or design of the facility, new equipment, hazardous materials,
  • processes are introduced that affect evacuation routes
  • new types of hazards are introduced that require special actions

Emergency Action Plan Basics

The actions taken in the initial minutes of an emergency are critical.

The Emergency Action Plan (EAP) or Emergency Response Plan (ERP) is an “action plan” to organize employer and employee actions during workplace emergencies.

Well developed emergency plans and proper employee training will result in fewer injuries and less structural damage to the facility during emergencies. On the other hand, a poorly prepared plan may lead to a disorganized evacuation or emergency response, resulting in confusion, injury, and property damage.

Almost every business is required by OSHA to have an emergency action plan (EAP). OSHA may require you to have an EAP if:

  1. fire extinguishers are required or provided in your workplace, and
  2. anyone will be evacuating during a fire or other emergency.

The only exemption to this is if you have an in-house fire brigade in which every employee is trained and equipped to fight fires, and consequently, no one evacuates.

In most circumstances, immediate evacuation is the best policy, especially if professional firefighting services are available to respond quickly. There may be situations where employee firefighting is warranted to give other workers time to escape, or to prevent danger to others by spread of a fire. In this case, the employer is still required to have an EAP.



Minimum Requirements of an Emergency Action Plan(EAP)

Producing a thorough emergency action plan that addresses factors specific to your worksite is straightforward. The first step when developing an emergency response plan is to conduct a risk assessment to identify potential emergency scenarios.

An understanding of what can happen will enable you to determine resource requirements and to develop plans and procedures to prepare your business.

Emergency Response Plan includes using what was identified and learned from the risk assessment and describing the way employees should respond to various kinds of emergencies, taking into consideration your unique worksite layout, structural features, and emergency systems.

The commitment and support of all employees is essential to the plan’s success in case of an emergency; request their assistance in creating and employing your emergency action plan. For smaller organizations, the plan does not need to be written and may be communicated orally if there are 10 or fewer employees. [29 CFR 1910.38(b)]

Evaluating Your Workplace

The best way to protect yourself and others is to prepare for an emergency before it happens by doing a thorough assessment of the workplace. Think about possible emergency situations and evaluate your workplace to see if it is sufficiently prepared using the following OSHA standards:

  • Design and construction requirements for exit routes29 CFR 1910.36. This standard contains requirements for the design and construction of exit routes. It includes a requirement that exit routes be permanent, addresses fire resistance-ratings of construction materials used in exit stairways (exits), describes openings into exits, defines the minimum number of exit routes in workplaces, addresses exit discharges, and discusses locked exit route doors, and exit route doors. It also addresses the capacity, height and width of exit routes, and finally, it sets forth requirements for exit routes that are outside a building.
  • Maintenance, safeguards, and operational features for exit routes29 CFR 1910.37. This standard includes requirements for the safe use of exit routes during an emergency, lighting and marking exit routes, fire retardant paints, exit routes during construction, repairs, or alterations, and employee alarm systems.
Learn more about Emergency Exits
  • Emergency action plans (EAP)29 CFR 1910.38. Again, the EAP facilitates and organizes employer and employee actions during workplace emergencies.
  • Fire prevention plans (FPP)29 CFR 1910.39. The purpose of the fire prevention plan is to prevent a fire from occurring in a workplace. It describes the fuel sources (hazardous or other materials) on site that could initiate or contribute both to the spread of a fire, as well as the building systems, such as fixed fire extinguishing systems and alarm systems, in place to control the ignition or spread of a fire.
Learn more about Fire Prevention Plans
  • Portable fire extinguishers29 CFR 1910.157. Workplace fires and explosions kill hundreds and injure thousands of workers each year. One way to limit the amount of damage due to such fires is to make portable fire extinguishers an important part of your fire prevention program. When used properly, fire extinguishers can save lives and property by putting out a small fire or controlling a fire until additional help arrives.
Learn more about OSHA standards for Fire Extinguishers
  • Fixed extinguishing systems29 CFR 1910.160. Fixed fire extinguishing/suppression systems are commonly used to protect areas containing valuable or critical equipment such as data processing rooms, telecommunication switches, and process control rooms. Its main function is to quickly extinguish a developing fire and alert occupants before extensive damage occurs by filling the protected area with a gas or chemical extinguishing agent.
  • Fire detection systems29 CFR 1910.164. Automatic fire detection systems, when combined with other elements of an emergency response and evacuation plan, can significantly reduce property damage, personal injuries, and loss of life from fire in the workplace. Its main function is to quickly identify a developing fire and alert building occupants and emergency response personnel before extensive damage occurs. Automatic fire detection systems do this by using electronic sensors to detect the smoke, heat, or flames from a fire and providing an early warning.
  • Employee alarm systems29 CFR 1910.165. The purpose of the employee alarm systems standard is to reduce the severity of workplace accidents and injuries by ensuring that alarm systems operate properly and procedures are in place to alert employees to workplace emergencies.
Learn more about Sheltering in place

Elements the Emergency Response Plan Must Include

but is not limited to the following elements [29 CFR 1910.38(c)]:

  • emergency action planMeans of reporting fires and other emergencies: Procedures for reporting a fire or other emergency. There are preferred procedures for reporting emergencies such as dialing 911, or an internal emergency number, or pulling a manual fire alarm but there are many other possibilities. [29 CFR 1910.38(c)(1)]
  • Evacuation procedures and emergency escape route assignments: Evacuation policies, procedures, and escape route assignments are put into place so that employees understand who is authorized to order an evacuation, under what conditions an evacuation would be necessary, how to evacuate, and what routes to take. Exit diagrams are typically used to identify the escape routes to be followed by employees from each specific facility location. [29 CFR 1910.38(c)(2)]
  • Procedures for employees who remain to operate critical plant operations before they evacuate: Employees may be required to operate fire extinguishers or shut down gas and/or electrical systems and other special equipment that could be damaged if left operating or create additional hazards to emergency responders (such as releasing hazardous materials). [29 CFR 1910.38(c)(3)]
  • Accounting for all employees after an emergency evacuation has been completed: Procedures to account for employees after the evacuation to ensure that everyone got out may include designating employees to sweep areas, checking offices and rest rooms before being the last to leave a workplace or conducting a roll call in the assembly area. Many employers designate an “evacuation warden” to assist others in an evacuation and to account for personnel. [29 CFR 1910.38(c)(4)]
  • Rescue and Medical Duties for Employees Performing Them: Most small organizations rely on local public resources such as the local fire department or hospital to provide these services. [29 CFR 1910.38(c)(5)]
  • Names or job titles of persons who can be contacted: Names, titles, departments, and telephone numbers of employees who can be contacted for additional information and/or explanation of their duties under the plan. [29 CFR 1910.38(c)(6)]

When writing an emergency response plan these additional elements may be helpful to consider:

  • A description of the alarm system to be used to notify employees (including disabled employees) to evacuate and/or take other actions. The alarms used for different actions should be distinctive and might include horn blasts, sirens, or even public address systems.
  • The site of an alternative communications center to be used in the event of a fire or explosion.
  • A secure on- or offsite location to store originals or duplicate copies of accounting records, legal documents, your employees’ emergency contact lists, and other essential records.
Check out: Emergency Response Plan Checklist

How and When to Train Employees on Emergency Action Plan Components

Training should be offered employees when you develop your initial plan and when new employees are hired. Employees should be trained or retrained as required when your plan changes due to a change in the layout or design of the facility, when new equipment, hazardous materials, or processes are introduced that affect evacuation routes, or when new types of hazards are introduced that require special actions.

General training for your employees should address the following:

  • Individual roles and responsibilities;
  • Threats, hazards, and protective actions;
  • Notification, warning, and communications procedures;
  • Emergency response procedures;
  • Evacuation, shelter, and accountability procedures;
  • Location and use of common emergency equipment; and
  • Emergency shutdown procedures.

You may also need to provide additional training to your employees (i.e. first-aid procedures, portable fire extinguisher use, etc.) depending on the responsibilities allocated to employees in your plan.

Conducting Drills and Retraining

If training is not reinforced, it will be forgotten. Consider retraining employees annually.

Once you have reviewed your emergency action plan with your employees and everyone has had the proper training, it is a good idea to hold practice drills as often as necessary to keep employees prepared. Include outside resources such as fire and police departments when possible. After each drill, gather management and employees to evaluate the effectiveness of the drill. Identify the strengths and weaknesses of your plan and work to improve it.

How to Complete a Risk Assessment

A risk assessment is a systematic examination of a task, job or process that you carry out at work for the purpose of identifying the significant hazards, the risk of someone being harmed and deciding what further control measures you must take to reduce the risk to an acceptable level.

  • Identifying the significant hazards that are present (a hazard is something that has the potential to cause someone harm or ill health).
  • Deciding if what you have already done reduces the risk of someone being harmed to an acceptable level, and if not;
  • Deciding what further control measures you must take to reduce the risk to an acceptable level.

Who should do risk assessments?

Risk assessments should be overseen by a person who is experienced and competent to do so, competence can be expressed as a combination of Knowledge, Awareness, Training, and Experience. As needed employees that work in the area should be consulted to help identify risks, as they are job experts in their area.

Remember competence does not mean you have to know everything about everything, competence also means knowing when you know enough or when you should call in further expert help.

8 steps to carrying out a risk assessment;

  1. Identify the hazards
  2. Identify those at risk
  3. Identify existing control measures
  4. Evaluate the risk
  5. Decide/Implement control measures
  6. Record assessment
  7. Monitor and review
  8. Inform

Look for the hazards that you could reasonably expect to result in significant harm, for example;

Slipping and tripping hazards from poorly maintained floors, Fire hazards from flammable materials etc.

Identify those at risk

Think about individuals or groups of people who may be affected e.g.

  • Office staff
  • Maintenance personnel
  • Members of the public
  • Machine operators

Particular attention must be paid to disabled staff, lone workers, temporary staff and young inexperienced workers.

Identify Existing Control Procedures

Examine how you already control the risks; it is unlikely that your workers are getting injured on a daily basis, so you must have some controls in place already. To decide if those existing control procedures are adequate, and to evaluate the risk, complete a risk ranking which will determine the residual risk.

Evaluate the risk

A risk is defined as the likelihood that a hazard will cause harm

I.e. Risk = Likelihood x Severity – below is an example of a simple 1-5 risk ranking system.

  1. Rare
  2. Unlikely
  3. Possible
  4. Likely
  5. Almost Certain

If the hazard does result in harm, how severe would the injury be?

  1. Scratch (trivial)
  2. Cut (Minor injury)
  3. Fracture (Major injury – Over 3 day injury)
  4. Amputation (Major injury)
  5. Death (Death)

Decide and Implement new control measures

If the risk is not adequately controlled decide which new control procedures are required and ensure these procedures are implemented. The control measures are the actions performed to reduce either the probability of the accident happening or the severity of the outcome, and where possible both. When considering what measures to put in place it is important to consider both severity and likelihood, in order to minimise the overall risk.

When deciding what new control measures will be required, it is helpful to work through the ‘hierarchy’ of controls. The hierarchy is as follows:

  1. Elimination – get rid of the risk altogether
  2. Substitution – exchange one risk for something less likely or severe
  3. Physical Controls – separation/Isolation, eliminate contact with the hazard
  4. Administrative controls – safe systems of work, rules in place to ensure safe use/contact with hazard
  5. Information, instruction, training & supervision – warn people of hazard and tell/show/help them how to deal with it
  6. Personal Protective Equipment – dress them appropriately to reduce severity of accident

Control measures should be practical and easy to understand (what to do and why they are doing it), applicable to the hazard, able to reduce the risk to acceptable levels, acceptable to the workforce and easy to operate.

Understanding the Hierarchy of Control will help you  better understand how best to mitigate risks

After you have implemented the new control procedures, then re–rank the risks as above to determine the new residual risk, you should aim to get the risk to as low as is reasonably practicable until it is at a tolerable level.

Record the assessment

Keep copies of the assessments for your records and for inspection by OSHA should they ever be requested. Retaining copies is also helpful in reviewing the risk assessment, at a minimum annually, or when it becomes imperative to add to it, such as when new equipment, or workplace layout changes.

Monitor and review

You must ensure that the control measures are achieving the desired level of control. You must review the assessment on a regular basis or if anything changes e.g. new staff, change in machinery or process.


Remember, even if you work in a seemingly low risk working environment, hazards exist and the risk management process is still an essential part of creating your safe work systems.

Mistakes in Managing Safety

The challenge of managing the many aspects of safety at work at times can feel overwhelming. There are many legal, moral, and financial reasons for us to pay attention to our safety obligations. With all these challenges we need to ensure that we are not wasting our time, money, and efforts doing things that simply don’t work. Here is a list of common errors we can make in managing workplace safety issues that hopefully we can all avoid.

10 Mistakes made while Managing Safety

(1) Celebrate the lack of injury and not the existence of safety.

It is a huge mistake to focus on the lack of injury as the measure that we’ve been safe. Everyone I’ve ever met can tell me of a situation when they have taken a terrible risk with their well-being and have gotten away with it. Of course, we should be happy when we’ve gone a period of time without anyone being hurt, but that doesn’t mean we were “safe”. Safety cannot be defined as a lack of injury. Safety is created by what we do, not what we avoid.

Too many companies reward the “lucky” who didn’t get hurt while being unsafe and the “liars” who don’t report injuries to avoid being the employee that breaks the safety record. We need more focus on making our work places safe by doing the safety activities it takes to create safety. Safety celebrations should be shared with those people who have helped make our workplaces safe and not those who have just been lucky!

(2) Do safety to our employees and not with them.

Rules imposed by others don’t often get the buy-in needed to change behavior. Involving employees in the process of establishing the safe behaviors and rules that apply to their workplaces makes it much more likely that those rules of behavior will be complied with. Challenging groups of employees to set and review the standards of performance involves them in the essentials of safety.

(3) Do safety only for the government.

Companies in the early stages of developing their safety cultures often make the mistake of being “reluctant compliers”. They are doing safety because the government is forcing them to do it. The value of managing safety is truly beneficial to a company’s bottom line productivity and performance. The sooner a company starts doing safety for the added value to their performance the sooner they will start to perform! Safety is about getting everyone home every night. Of course, how we do that should follow the applicable OHSA regulations. Don’t do safety for the government, make your work safe and make it legal… your company will thrive financially because of it.

(4) Ignore the importance of the proper tools, equipment, materials and work space.

The historic myth that unsafe behavior causes 88% of the incidents we experience is simply NOT true. Unsafe behaviors are involved in ALL incidents we experience. The other part of the formula that is often ignored by believing in this myth is that unsafe conditions are also always present. We need to focus our efforts on both safe behaviors and safe conditions (tools, equipment, materials and work environment). If we only supply broken tools to humans, we shouldn’t be surprised when they get hurt. If we don’t supply an easily accessible lifting machine for employees to use, we shouldn’t be surprised when they are injured by over lifting. Good tools and equipment increase the chances that workers will do their work by not taking unnecessary risks.

(5) Ignore the culture of unsafe behavior.

Not making safe behavior personal and not holding each other accountable for making it safe at work is a huge mistake. Allowing our fellow employees to continue unsafe behaviors is often disastrous. We are our brothers and sisters’ keepers. Not unlike when we play team sports games, we must take the opportunity to coach our fellow employees who are missing the safe behaviors they need to do so they go home safely every night.

A safety culture can make or break your workplace, literally. You need to formulate a plan for improving your safety culture.

(6) Miscalculate the power of groups actively caring about each other.

Inviting co-workers to give us feedback and coaching when they see us doing something unsafe is a wonderful way to increase the team approach to safety. Unless invited, our coworkers may feel reluctant to bring our mistakes to our attention for fear of a poor reaction. We’re in this together so why not open up the discussion and invite each other to help us through the challenges of behaving safely.

(7) Deliver Safety Programs to passive employees.

I’m not sure what happened historically to make us believe that we could deliver safety to employees like a pizza. The sooner we hold everyone accountable for safe production and not just production with safety added on, the better off we’ll all be. Challenging employees to come up with the ways to make their work safe is well documented as a sure fire way to increase your safety performance.

(8) Measure results and not the activities that create safety.

Companies who define safety activities for all of their staff throughout their organizations (including the CEO) are safer than those who don’t. Demanding that the measurement of doing a great job includes doing safety tasks like: investigations, hazard assessments, inspections and attending meetings, gets what needs to be done, actually DONE. Not doing this ensures that safety activities will take a back seat to production every time.

Learn more about measuring workplace safety.

(9) Manage OHS differently than we manage the other parts of our businesses.

Why would a profitable successful company with a clear record of managing success implement a “safety program” that doesn’t EXACTLY replicate why they are successful in the first place? Manage safety exactly like you manage your business and you’ll get similar results. There are too many companies that manage safety differently than their business to the peril of their safety results.

If you know how your employees and management team are motivated to give you production, why would you settle for doing something different to get safety results?

Far too often companies take a very positive and proactive approach to motivating productivity activities yet do exactly the opposite when it comes to safety by providing only negative reinforcement for safety. Safety is a condition of employment is a commonly used threat. Of course, it is, and so is being on time and doing your job. Too many companies in their orientation focus on making negative consequences the key messages during orientation rather than to tell employee that we need their help to make it safe here and we are counting on you to help us with safe production. Of course, you cannot ignore unsafe behaviors any more than you would ignore behaviors that didn’t comply with your productivity systems. Stop making safety feel like a negative thing. There is nothing negative about doing our work with a focus on safe production.

(10) Hold safety meetings that everyone wants to avoid.

I have spoken to tens of thousands of employees in my career about the functionality of the “safety meetings” that they attend. Overwhelmingly people tell me they don’t like what goes on in these meetings very much. The natural question is “Why are we going to a meeting and not liking what is going on?” Simply fix it! At your next meeting stand up and tell folks you’d like to discuss how to make these meetings better. Let’s all set a goal of not sitting silently at a meeting that isn’t addressing our needs. Just say NO to unsuccessful safety meetings!

Learn more about engaging your employees on safety committees.

Well there you have it. I hope you have some ideas to think about to make your safety culture better. Own the safety process, take part in creating it, stand up and be counted. We need to do this together and stop doing things that we know fail. Let’s be successful together… it matters a lot to you and the people that you work with!

Lower Experience Modification Rate for Increased Profits

This is part 2 of our series on EMR and how it is effecting the profitability of your company. For Part 1, click here.

Is your company looking for a way to increase profitability? Before you cut personnel, before you look for ways to cut expenses, before you try anything else, have you looked at your Worker’s Compensation insurance rate? This is called the experience modification rate, and is calculated based upon your risk rating. To learn more about how your EMR rate is calculated, check out part 1 of this series.

An above average experience modification rate (EMR), can be costing your company valuable profit, and if you’re not aware of it, this can be a hidden profit suck.

So, what can you do?

It isn’t as easy as lowering your car insurance by just switching companies, because the EMR follows your company from insurance company to insurance company. It is a multiple stage approach, which I will lay out for you.

Steps to Lower Experience Modification Rate

The first step is to do a claims review. Many companies request a claims review, then sit there and nod their heads as the company presents the information, which is honestly useless. Just being told about the information doesn’t help you. You need to understand the information and how it can impact your company.

  • Was this person or are they currently an employee?
    • It occasionally happens where an employee is assigned to the wrong company, so ensure all listed people are properly assigned.
  • When was last claim payout? Is it an opportune time to settle the case?
    • Why would you settle a claim? Settlement of a claim can lower the impact it has to a claim. If a case was assigned a reserve of $100,000, and has paid out $3,000, there is a reserve of $97,000 which is reflecting on the claim as a high claim case. A settlement of $10,000 would close the case at a value of $13,000, bringing back $87,000 and lowering the impact to the EMR.
  • Review of class codes.
    • Every employee has a class code under which they are assigned, and ensuring they are properly accounted for in payroll records for hours worked is important for a proper EMR calculation. Why is this so important? If you run an auto repair business, a mechanic has a naturally higher risk classification than an accounts receivable clerk, if someone in your business covers both positions, classifying them under the higher risk code could lower the XMOD calculation simply by having less injuries for a higher risk classification code.

If you have made any corrections or adjustments during this process, have the EMR recalculated, and this could save your company thousands.

With the claims review completed, it is time to conduct a trend analysis.

When just starting in this process, the information will be basic. It will come from your worker’s compensation auditor, during the claims review. What you’re looking for, are accidents increasing or decreasing? Any identifiable patterns to claims/injuries; such as 40% are lifting improperly or such?

As your program matures, you can include items like Near Miss reports, location first aide only incidents, safety committee findings, or anything else your company builds up.

Once you have conducted a thorough tend analysis, the next step is to design a Return to Work (RTW) Program

A Return to Work Program is invaluable to lowering an Experience Modification Rating. It decreases associated costs to provide employees with light duty work, because wages are paid directly to the employee vs paying them from insurance. This decreases the costs paid out by insurance, which is a factor in calculating the EMR.

When implementing a RTW program, it is important that the employee serves a valuable job function, so as to add value to your company, but you also have to take into consideration that the job is within the person’s skill set, and the job is not seen as punitive. What? Yes, some tasks can be seen as punitive, like if the worker is reassigned to a task that provides no value to the company. Companies have done things like having workers sort nuts & bolts, then at the end of the day they mix everything together again. A task like this could be seen as punitive towards the employee, and could have your company under scrutiny for punitive or vindictive actions towards an injured employee.

Keep this in mind while managing a Return to Work Program, and design a program that aids the employer and employee.

Next step in this process is establishing a strong safety program.

When establishing a safety program this is a multi-faceted approach, allow me to lay this out for you:


Following these steps, your company will be able to lower your company’s Experience Modification Rate, which translates into increased profits, and a safer workplace for all employees.

Keep in mind, besides fixing errors, making a change to an EMR is not an instantaneous process, and it will take at least a year to see the impact, while it can take 2 years to see marked improvement, due to getting information to the field employees and building a full and proper safety culture.

Experience Modification Rate Explained

In today’s competitive world of business, it is necessary for companies to take every precaution relating to insurance claims and the efficiency of their safety programs.

Workers compensation insurance is mandatory in every state. The premium depends upon the state, the industry, and other factors like your Experience Modification Rating, XMOD, Experience Mod, or EMR. The Experience Modification Rating is a formula that compares the claims and costs of worker’s compensation in your company to other businesses that are similar in terms of size and capital.

Workers’ compensation and how businesses deal with it is becoming increasingly important, as this can impact the profitability of the company. Understanding and tracking this rating will help you discern how well your loss prevention practices work and can help you lower your rates.

How Experience Modification Rating Affects Profits

Experience Modification Rating is a way of rewarding or penalizing companies for their safety management. The lower your rating the lower your workers comp rates will be, while the higher your rating the higher your workers comp rates will be.

Employers that on average have a yearly premium that meets or exceeds $3,000 will often be supplied with an Experience Modification Rating. Each year, your Experience Modification is calculated by the NCCI (National Council on Compensation). In most instances, your rating is calculated using the three past years of date supplied by your insurance company. So for example, your 2019 EMR would be calculated based upon all claims from 2018, 2017, and 2016.

If your yearly premium is $100,000 and your Experience Mod is 1.20, then your premium will increase by $20,000 for that year, making your annual premium $120,000. Conversely, if your rating is.80, then your premium will decrease by $20,000 for that year, making your annual premium $80,000. As you can see, your workers compensation insurance rate is greatly impacted by this rating. So, if you’re trying to compete for business, or remain profitable in a competitive market, an XMOD of 1.20 could put you $40,000 behind, meaning if you have a margin of 35%, you would need an additional $114,285 in sales to just offset this loss.

How is the Experience Modification Rating calculated?

Having no claims is best. However, most companies do have some type of claim. Medical-only claims that don’t involve loss of time are reduced by 70% before being figured into the equation.

I will to attempt to explain the experience modification factor in layman’s terms. I’m not going to delve into the formula and its components but rather only those pieces that you have direct control over. I’ll touch on classifications, payrolls and losses.

Class Codes

Just like anything, without the proper foundation all things will crumble. This is definitely the case with your class code. If you have the wrong class code then you’ll have the wrong mod. As agents, we use the Scopes manual to give us class code descriptions and rules. You should ask to see the narrative for your specific code(s). Only then can you determine if you are properly classified. Some classifications allow for a division of payroll. In several states most of the codes allow for division of payroll. What I mean by this, if you fit into two (or more) codes, you can divide the payroll between them as long as you maintain separate payroll records. It would behoove you to do so, otherwise all of your payroll will go into the higher rated classification. Why pay more if you don’t have to?


Payroll is another component that you control. Your payroll is your payroll. What you need to make sure of is that the auditor has assigned the proper payroll to each class code. Sounds rather simple doesn’t it? Don’t let if fool you. Did the auditor include overtime premium pay? He shouldn’t have. Is there division of payroll? Don’t rely on them to tell you about these things because they won’t.


For those of you who’ve had a bad experience with experience rating, you’re sure to know it’s the losses that were the primary culprit in your debit mod. Nothing affects your mod more so than the loss component. Do you even know what your losses are? Do you have any open claims? Do you have any losses that will be dropping off your next mod calculation? Are you picking up a bad year? Did your insurer recover any money through subrogation? Were any of your losses over-reserved? If there’s one thing to remember from this article, it is to stay on top of your losses.

The first $5,000 of each loss of time claim is counted at full value, and anything over that is discounted. This means that your Experience Mod is less affected by a large single claim than it is by multiple small claims.

So, what can you do to improve your Experience Modification Rate (EMR)?

Check out our suggestions here for how to lower your EMR.


As you can see, the XMOD of your company is not some crystal ball calculation, and is really just an overall insurance look of risk for your company. Understanding this, and looking at it as a simple mathematical calculation, will provide you with an understanding of how to lower your costs and increase your company’s profitability.

How to Improve Your Safety Culture

According to the Broken Windows Theory of Crime, if a broken window is left unrepaired, people walking past it will assume no-one is in charge. Within a short space of time, more windows will be broken creating a subtle indication that anything goes.

Crime is contagious and works like an epidemic.

So, if a broken window attracts more crime, does this mean that a workplace that is poorly cared for has more injuries?

And the answer is simple: yes.

According to a study by Dave DeJoy and Todd Smith from the University of Georgia’s College of Public Health, they found a well-kept site means safety is a priority.

Crime is contagious. So is not caring about where you work and the safety of your workmates. Organizations that allow untidiness and broken equipment are subconsciously saying that safety and equipment aren’t important. By fixing up the little things in your environment (e.g.: broken/unsafe machinery, PPE that needs replacing), you fix up the safety culture.

High performance companies keep their workplace cultures in check by balancing core areas. These are Unity, Compassionate Leadership and Communication. Together, these factors hit the sweet spot for trust (which is when people feel safe). Trust is integral for a high functioning culture.

As Simon Sinek says in “Start with a Why”, “only when individuals can trust the culture of an organization, will they take personal risks to advance the company. Great organizations become great because the people inside feel protected”.

This desire “to feel safe” is two-fold, it means feeling safe to excel and take risks in your career, but also knowing that you are protected from getting injured at work or from being bullied or harassed by colleagues.

3 Simple Steps to improve safety culture

To get to “Trust”, companies need to align themselves with the following three inter-related factors that are driven from the top, but are orchestrated at every level:

1.Unity– High performing workplaces are unified and have every-one working together as a team. There is no “Us versus Them” mentality.

Humans have a very strong and instinctive desire to be part of something bigger than themselves. It’s the same at a workplace. Staff want to be part of a group and a successful one that’s going somewhere. It’s important for companies to cultivate a strong sense of group identity. This means that all communication uses the terms “we” and us” and that clear goals are set.

2.Compassionate Leadership– We all need to feel loved and appreciated. It’s important that companies convey this to their staff. Not just through words, but through the right actions.

Staff and even visitors, to your workplace, will look for visible signs that staff are highly valued to the organization.

This means looking for evidence of:

  • A tidy, clean kitchen and toilet area,
  • Clean workspaces,
  • Operational equipment,
  • Clean PPE, and
  • Happy staff working together.

By ensuring a tidy work environment and operational equipment, leaders ensure that subtle messages are given that only productive and safe behaviors are tolerated.

Other more intrinsic signs are that staff ‘s personal needs are considered important and that they are listened to, if they have any concerns.

3.Communication– Finally, we have the final step that communicates the other two areas but in a transparent, predictable manner. This is where communication connects staff emotionally to the information by using stories and metaphors.

Communication must be regular and transparent. Woe betide any CEO who dares to announce that safety is important, but in a later announcement declares that due to poor sales, the safety budget is going to be cut. Messages must always be transparent and credible.

They must also include:

Unity messages that working at the company is a team effort, that group goals are achievable and that looking out for teammates is required, while being responsible for your own safety.

Compassionate messages that the company wants the best for staff, that staff contributions are welcomed, and that safety is a priority.

Communication is also open at all levels and staff can offer feedback that is actioned rather than ignored.

By ensuring that these three factors are in balance, organizations ensure that their workplace is highly functional and cohesive, with trust being the centerpiece of how the organizations operates.

Security Policies and Security Documentation

This document is prepared and presented as a basic overview of contemporary best practices regarding written documentation — primarily security policy – needed within an effective security program. It is generic in that it is developed without a specific application or facility in mind. As such, all or parts of this information may not be appropriate for every building or facility. The intent is to provide fundamental information for non-technical and non-security readers.

Security documentation is the written material used to govern all aspects of a security program. Such documentation would include, at minimum, the following;

  • Policies
    • Standards
    • Guidelines
    • Emergency Plans
    • Training Material
    • Informational Material


It can be said that there are – in essence – only 3 reasons for performance failure in an organization’s security program;

(1) The is NO policy and procedure addressing the issue;
(2) There is a policy and procedure addressing the issue, but it was not followed;
(3) The policy and procedure addressing the issue was followed, but the contents were inadequate to properly address the circumstances of the particular situation.

In the triad of architectural, technological and operational security, the policies and procedures are the foundation of the later and are easily the most overlooked and most important aspect of a comprehensive and effective security program.

An organization’s policies and procedures are dynamic in that they must be continuously updated and constantly refined. Perhaps no other single aspect of an entity more clearly reflects its culture and philosophy than the body of written policies and procedures by which it governs.


Easily, the most common obstacle in any attempt to develop security policies and procedures is the failure to have the full support of top management. At the very least, the direct approval of the top position is necessary. Ideally, the policies and procedures should be reviewed and approved by the governing body – such as the Board of Directors – or a committee thereof. This support from the top of the organization must also be clearly reflected in the document itself.

Additionally, management must support the effort through “example”. This means that the policies and procedures must apply to everyone, regardless of their position within the organization. If exceptions are to be allowed, the exceptions should be stipulated in the policy and procedure document.


If a “perfect” policy and procedure document could ever exist, even it would be of no value if the person’s subject to its contents and responsible for its implementation and enforcement are not aware of the details. Traditionally, binders of printed documents were reproduced and widely distributed so as to be accessible to the workforce. Today, fewer printed copies are prepared and there is a greater reliance on electronic media. A best practice is for the security department to have its own website on the organization’s intranet. Among the many benefits of this is the ability to make the security policies and procedures readily available for reviewing and downloading, ideally in the Adobe.PDF format.

The essential contents of the policies and procedures should also be presented during employee orientations and included in an employee handbook.


Typical security documentation can be described as follows:

POLICY: The organizations stated security objectives and the requirements in general terms. Policy also establishes departmental responsibilities and cooperative interaction where issues may overlap. Most importantly, it conveys authority. Policies address specific issues, however, the statements are usually very broad and without detail.

STANDARDS: Standards establish minimum performance parameters. These are statements that are usually “actionable”, “measurable” and/or “observable”. Standards are more detailed that Policies, and can often be the same as or similar to technical specifications.

GUIDELINES: Policies and standards require writing in a very precise and special way that avoids misunderstanding. Because it is not a narrative style that most people are accustomed to reading, some helpful explanatory notes can aid in comprehension. Guidelines serve this purpose but are not “requirements” in themselves.

PROCEDURES: Procedures are directed at persons responsible for taking action under the various circumstances and conditions, or in response to certain events. These are very specific and step-by-step to the extent practical and reasonable. Where Policies and Standards may apply on an enterprise-wide basis, there will always be a large portion of the Procedures that must be specific to each individual location or facility.

EMERGENCY PLANS: Generally, a given facility will have need for several emergency plans, each addressing specific events. Emergency plans are constructed – in part – so that they may be referenced in real time during an event. The most common emergency plans are in response to such things as a fire or bomb threat. Additional plans may be needed for other events such as an attack or when the threat of attack is elevated. Procedures within Emergency Plans tell people “where” they will go and “what” they will do when the get there.


A key aspect to a good manual is that it is relatively easy for any user to find the information they are seeking. Because a policy and procedure document is continuously revised, a conventional, single document with sequential page numbering would be less than optimal. Additionally, it is desirable to numerate the contents other than through the employment of page numbers, since these tend to change during revision. It is also very desirable to facilitate later reference to individual “provisions” within the document, similar to the manner in which government laws are numerated. An example structure might be something similar to the following:

1 = Chapter
1.01 = Subchapter
1.01.01 = Section = Subsection

It is advisable to create a standard format or template for the pages in order to facilitate the replacement of pages with revisions, and for readability. The template should incorporate a place for the title of the chapter and a place the date of the most recent revision. The document should contain a Table of Contents and a word index is a great enhancement.

Typically, an organization would have a general or master body of policies and procedures that are universally applicable across the entire global enterprise. Entities with multiple facilities will likely need to reserve certain subjects for further individualization for various locations such as different cities, states or countries in order to accommodate variations in applicable laws.

Additional policies and procedures will usually be needed based upon the specific nature of the organization, such as the business or industry in which it falls. Government regulatory compliance can be a major element of the document in some operations.

Where the policy manual is separate from the procedure manual – as is generally recommended – the relative procedures should reference the corresponding policy.


There are a myriad of subjects that might be addressed in a comprehensive set of security policies and procedures. Many of the common subjects will overlap with areas commonly addressed by the Human Resources department, and sometimes with other units as well. It is strongly recommended that legal counsel review and approve all policies prior to dissemination.

Typically, policy is written in a narrative and semi-general format and the only “rule” is that the message be clear and unambiguous. Each policy would generally state the organization’s position on the subject, and most importantly, it should delegate the necessary authority and responsibility for developing the corresponding procedures for execution and enforcement.

Procedures are typically written in a “step-by-step” format. As a guide, security procedures for security officers should be developed with a new guard on his or her first day on the job in mind.


If policies are important, than adherence to policy must be equally important. The policy MUST set forth appropriate consequences for violations of any policy, in the form of disciplinary action. Failure to consistently enforce policies might tend to negatively impact the legal enforceability of all policies. Where an organization lacks the collective will to act to enforce a policy, that policy should be changed or abolished. No policy should ever continue to exist for which enforcement action is not instituted consistently.


No policy and procedure manual can be completely written in advance that will be applicable to any organization without customization and modification. The following is a list of basic subject areas – not in any specific order – that should be considered for inclusion in a security policy and procedure manual;

1.0 Statement from Executive Management
2.0 Security Department Mission, Purpose and Objectives
3.0 Security Department – General
3.1. Organizational Structure
3.2. Policy Enforcement
3.3. Investigations
3.4. Reporting
3.5. Background Investigations
3.6. Use of Force
3.7. VIPs
3.8. Communications
4.0 Security Department – Management
4.1. Authority
4.2. Qualifications
4.3. Liaison with Government Agencies
4.4. Periodic Departmental Reports
4.5. Security Awareness Training of Non-Security Personnel
4.6. Responsibilities
4.7. Staff Performance Appraisals
5.0 Security Department – Staffing
5.1. Qualifications
5.2. Uniforms
5.3. Equipment
5.4. Training
5.5. Post Orders
6.0 Security Department – Duties and Responsibilities
6.1. Policy Enforcement
6.2. Investigations
6.3. Response to Criminal Acts
6.4. Suspicious Persons
6.5. Emergency Conditions
7.0 Information Protection
7.1. Document Storage for Business Continuity
7.2. Document Destruction
7.3. “Clean Desk” Program
7.4. Trash Removal
8.0 Lost and Found
9.0 Courtesy Escorts
10.0 Cash Handling
11.0 Parking and Traffic Control
11.1. Vehicle Registration
11.2. Signage
11.3. Vehicle Removal
12.0 Security Responsibilities of All Employees
12.1. Reporting Incidents & Suspicious Situations
12.2. Cooperation in Investigations
12.3. Privacy and Consent to Search
12.4. Contacts by Governmental Agencies
12.5. Contacts by the Media
12.6. Cooperation during Emergencies
12.7. Protection of Assets
12.8. Prohibited Items
12.9. False Reporting Prohibited
12.10.Employee Conduct
13.0 Lock and Key Control
14.0 Material Passes
15.0 I.D. Credentials
15.1. Employees
15.2. Visitors
15.3. Vendors / Contractors
16.0 Workplace Violence
17.0 Ethics
18.0 Medical Emergencies
19.0 Fire and Life Safety
19.1. Systems Inspection & Testing
19.2. Unsafe Conditions
20.0 Audits of the Security Department
21.0 Access Control
22.0 CCTV
22.1. Overt Surveillance
22.2. Covert Surveillance
23.0 Security Screening
23.1. Pedestrians
23.2. Vehicles
23.3. Parcels and Packages
24.0 Emergency Conditions
24.1. Preparation of Emergency Plans
24.2. Incident Command
24.3. Drills and Exercises