Category: Management

Your employer has many responsibilities or obligations detailed within the OSH Act and other standards. OSHA’s job is to protect employees, not necessarily employers. If there is a serious accident in the workplace, OSHA will investigate to determine if the employer did not adequately meet their obligations under the law. By doing so, OSHA’s ultimate goal is to protect you, the employee.

With this in mind, your employer must meet the following obligations to employees:

• Provide a workplace free from recognized hazards and comply with OSHA standards.
• Provide training required by OSHA standards.
• Keep records of injuries and illnesses.
  • Set up a reporting system.
  • Provide copies of logs, upon request.
  • Post the annual summary.
  • Report within 8 hours any accident resulting in a fatality.
  • Report any work-related hospitalization, amputation or loss of an eye within 24 hours.
• Provide medical exams when required by OSHA standards and provide workers access to their exposure and medical records.
• Not discriminate against workers who exercise their rights under the Act (Section 11(c)).
• Post OSHA citations and hazard correction notices.
• Provide and pay for most PPE.

Employer OSHA General Responsibilities

Your employer must provide a workplace free from recognized hazards and comply with OSHA standards. Establishing a safe and healthful workplace requires every employer to make safety and health a core value. In general, OSHA requires employers to:

• Maintain conditions and adopt practices reasonably necessary to protect you on the job. The first and best strategy is to control the hazard at its source. Engineering controls do this, unlike other controls that generally focus on the worker who is exposed to the hazard. The basic concept behind engineering controls is that, to the extent feasible, the work environment and the job itself should be designed to eliminate hazards or reduce exposure to hazards.
• Be familiar with the standards that apply to their workplaces, and comply with these standards.
• Ensure that you are provided with, and use, personal protective equipment (PPE), when needed. PPE is needed when exposure to hazards cannot be engineered completely out of normal operations or maintenance work, and when safe work practices and other forms of administrative controls cannot provide sufficient additional protection. PPE may also be appropriate for controlling hazards while engineering and work practice controls are being installed, and
• Comply with the OSHA’s General Duty Clause where no specific standards apply. The general duty clause, or Section 5(a)(1) of the Act requires each employer to “furnish a place of employment which is free from recognized hazards that are causing or are likely to cause death or serious physical harm to employees.”

Check Out: How to Conduct a Job Hazard Analysis to identify PPE needs

Employers Must Provide PPE

OSHA requires that employers protect you from workplace hazards that can cause injury or illness. When engineering, work practice and administrative controls are not feasible or do not provide sufficient protection, employers must provide personal protective equipment (PPE) to you and ensure its use.

• With few exceptions, OSHA requires employers to pay for personal protective equipment used to comply with OSHA standards.
• Employers cannot require workers to provide their own PPE
• The worker’s use of PPE they already own must be completely voluntary.
• Even when a worker provides his or her own PPE, the employer must ensure that the equipment is adequate to protect the worker from hazards at the workplace.

Employers are not required to pay for some PPE in certain circumstances:

• Non-specialty safety-toe protective footwear (including steel-toe shoes or boots) and non-specialty prescription safety eyewear provided that the employer permits such items to be worn off the job site. (OSHA based this decision on the fact that this type of equipment is very personal, is often used outside the workplace, and that it is taken by workers from jobsite to jobsite and employer to employer.)
• Everyday clothing, such as long-sleeve shirts, long pants, street shoes, and normal work boots.
• Ordinary clothing, skin creams, or other items, used solely for protection from weather, such as winter coats, jackets, gloves, parkas, rubber boots, hats, raincoats, ordinary sunglasses, and sunscreen
• Items such as hair nets and gloves worn by food workers for consumer safety.
• Lifting belts because their value in protecting the back is questionable.
• When the employee has lost or intentionally damaged the PPE and it must be replaced.

Employers Must Provide Training

We already discussed your right to receive training from your employer on a variety of health and safety hazards and standards, such as chemical right to know, fall protection, confined spaces and personal protective equipment.

Many OSHA standards specifically require the employer to train workers in the safety and health aspects of their jobs. Other OSHA standards make it the employer’s responsibility to limit certain job assignments to those who are authorized, certified, competent, or qualified – meaning that they have had special previous training, in or out of the workplace as follows:

• Authorized person – means a person approved or assigned by the employer to perform a specific type of duty or duties or to be at a specific location or locations at the jobsite.
• Certified Person – is one who has passed stringent written and practical exams related to the work that he will perform. OSHA requires the organization providing the examinations be accredited.
• Competent person – means one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.
• Qualified person – means one who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated his ability to solve or resolve problems relating to the subject matter, the work, or the project.

OSHA construction standards include a general training requirement, which states: “The employer shall instruct each employee in the recognition and avoidance of unsafe conditions and the regulations applicable to his work environment to control or eliminate any hazards or other exposure to illness or injury.” Additional general training requirements for construction include training for workers:

• required to handle or use poisons, caustics, and other harmful substances;
• who may be exposed to job sites where harmful plants or animals are present;
• required to handle or use flammable liquids, gases, or toxic materials; or
• required to enter into confined or enclosed spaces.

Check out: How to Put Together a Workplace Safety Training Workshop

Employers Must Keep Records of Injuries and Illnesses

Recordkeeping is an important part of an employer’s responsibilities. Keeping records allows OSHA to collect survey material, helps OSHA identify high-hazard industries, and informs you, the worker, about the injuries and illnesses in your workplace. About 1.5 million employers with more than 10 employees must keep records of work-related injuries and illnesses. Workplaces in certain low-hazard industries such as retail, education, finance, insurance, and real estate may be partially exempt from routine recordkeeping requirements.

For more information on updated exemptions see this OSHA Fact Sheet.

To meet OSHA reporting requirements, employers must do the following

• Set up a reporting system.
• Provide copies of logs, upon request.
• Post the annual summary.
• Report within 8 hours any accident resulting in a fatality.
• Report all work-related hospitalizations, amputations, and loss of an eye within 24 hours.

Make sure your company representatives are well trained on reporting, training available here

I offer an OSHA recordability flowchart, which will help you identify which injuries to report.

Employers Must Post OSHA Citations and Hazard Correction Notices

An OSHA citation informs the employer and workers of the standards violated, the length of time set for correction, and proposed penalties resulting from an OSHA inspection.

Your employer must post a copy of each citation at or near places where the violations occurred for 3 days or until the violation is fixed (whichever is longer).

Employers also have to inform workers of what they have done to fix the violation, allow workers to examine and copy abatement documents sent to OSHA, and tag cited movable equipment to warn workers of the hazard.

Emergency/Crisis Management Planning needs vary with the industry, type of operations, and regulatory applicability; however, the following guidelines can be used for any situation:

WHAT ARE YOUR WORKPLACE HAZARDS?

The first step is to Identify vulnerabilities and hazards associated with your operation. No one understands your operation better than you. Ensure that emergency, business continuity, and security issues are considered and use this analysis to prioritize your plan development efforts.

• You should consider the following topics, at a minimum:
• What are your vulnerabilities to natural disasters? Depending on the geographic scope of your operation, you may be subject to hurricanes, earthquakes, tornadoes. floods, ice storms, or all of these.
• How would your company continue to operate in the midst of a pandemic situation?
• What are the hazards introduced by your operation, and who may be impacted from a fire, release of hazardous material, oil spill, or explosion? Consider various events involving similar types of operations involving other entities, not the fact that it may have never happened in yours.
• In the event that your primary or corporate office becomes uninhabitable due to a fire, flood, hurricane, earthquake, power failure or other event, could your company to operate?
• What are your security vulnerabilities?

WHAT TYPE OF EMERGENCY PLANS SHOULD BE DEVELOPED AND AT WHAT LEVEL?

The next step is to use the results of the Hazard Analysis performed above, and determine what plan types should be developed, and which should be developed on a facility level or corporate/enterprise-wide level. For instance, site-specific fire pre-plans may be valuable for buildings and storage tanks that contain flammable contents; business continuity plans may be applicable at the corporate level.

Does your company need more components of an emergency action plan? Check what is available here

Example programs may include the following:

FACILITY LEVEL PLANS

• Emergency Response Plans (industrial operations), Emergency Operations Plans (hospitals, schools and universities), Emergency Action Plans (office building) describing site-specific initial response and activations procedures for potential hazards.
• Fire Pre-Plans for buildings and process equipment, if applicable.
• SPCC, OPA 90 Plans, RCRA Contingency Plans, SWPPP and other regulatory plans for facilities that store oil.

CORPORATE/ENTERPRISE-LEVEL PLANS

• Crisis Management Plans describing corporate procedures for supporting operational emergencies, and for responding to corporate crises, including security, product liability, financial and other reputation issues.
• Business Continuity Plans for corporate and regional offices
• Pandemic Plans (often included as a subset of Business Continuity Plans)

HOW SHOULD THE PLANS BE ORGANIZED AND WHAT IS THE APPROPRIATE LEVEL OF DETAIL?

Identify applicable regulatory requirements and ensure that your program addresses them, but remember that the primary purposes of the plans are to enable your company to respond effectively, and in the process, to ensure compliance. A common mistake is to organize plans specifically to meet the order of the regulations, when in fact, this may not result in the most logical or user-friendly format. Keep in mind that some regulations require a specific plan format or order of content, however, in many cases there is flexibility to organize the plan differently, as long as a regulatory cross-reference is provided and clearly identifies where each requirement is addressed.

Develop plans in a logical format that will be intuitive to responders who may not have had time to review them or training. A good test is to provide the plan to someone outside the organization and find out how long it takes for them to find key response information.

Ensure that plan content is comprehensive enough to provide tools needed for a response but is not so detailed that it reduces the effectiveness of the plan and results in more plan maintenance than necessary. Consider providing references and/or hyperlinks to detailed technical or regulatory information that may be needed but is too detailed to include in the plan.

Develop the content in a streamlined format with the goal of reducing the time required to read it. Bullet points and checklists are favorable to paragraphs of information.

OSHA offers publication 3088 to help organizations plan for emergencies and evacuations.

Download and view the OSHA Emergency Whitepaper below:

A safe working environment is a condition or state, it is not necessarily an event like an incident of an accident. This means that the low number of incidents or accidents doesn’t mean that the workplace is particularly safe. What really counts is the process of safety because it is an integral part of everyday activities in the workplace.

10 Essential Components for a Safer Working Environment

• Daily safety briefings. Every morning at the beginning of the work day or the shift, the leader holds an interactive safety briefing with his or her team. It lasts less than 10 minutes and has contributions from the team members.

Check out the toolbox talks I have for sale on Amazon here

• Weekly inspections to identify unsafe conditions. Every staff member participates in turn and conducts a regular safety inspection where they look for hazards and unsafe conditions. This can occur weekly or twice a week.
• Weekly inspections to identify unsafe behavior. Each week two staff members carry out a regular inspection where they are identifying unsafe behavior. The objective is to identify the unsafe behavior and mention it at the next daily safety briefing. Of course, no names are mentioned.

Check Out: How to Develop an Internal Safety Audit Schedule

• Accident and incident investigation. Every accident or near accident is investigated with the sole objective of prevention in the future. The process of investigation is not a witch hunt to apportion blame.

Want to learn more about Incident Investigations? Check out what I have available here.

• Constant improvement. During the daily safety briefings, the group members have an opportunity to recommend and discuss improvements to the workplace and the processes that are carried out within it
• Reporting near miss. Every single near miss (this is an incident where no damage or injury occurs) is investigated and prevention measures are put in place, so it will not happen again.

Check Out: Near Miss Policy

• Positive reinforcement. Each day the leader goes into the workplace and gives positive reinforcement to those members of staff for working safely. This encouragement and enthusiasm for safety is a great motivator for safe working practices.
• Blame. It is noticeable that all safe working environments do not use blame or punishment as tools for creating safe behavior. Instead, they use positive reinforcement, encouragement and recognition.
• Practical on-the-job training. Group members are continually receiving on-the-job training from experts within the company and outside.
• Effective leadership. It is no coincidence that all safe workplace environments have good leadership. This means that the leader is prepared to listen and has the skills to create followers. These leaders engender cooperation and most of all discretionary effort. They are the main reason why people are working safely. They are not invisible and spend between 30 and 50% of their time with their team members.

An internal safety audit program is used by an organization to evaluate the effectiveness of the procedures and processes used to meet OHS legislative and other statutory administrative requirements.

An internal safety audit schedule is a considered approach by an organization to identify the extent and methods by which to conduct safety related audit verification activity. The internal audit is also global best practice in safety management systems.

It’s also a vital internal quality check on safety systems and operations. The internal safety audit is a particularly useful management tool for ensuring that the safety management is being conducted efficiently and properly at all levels.

A senior manager should actively participate in the internal audit to ensure currency of management information and proper critical organization-wide scrutiny of administrative and operational functions.

Internal audit scope

The organization will need to identify the types of internal audit activity to be conducted.

These can include one or more of the following audit activity types:

• Safety management system (SMS) audit – system level
• Procedural compliance audit – operational level
• OHS legislative compliance audit – analyzing compliance capability
• Incident management
• Reporting systems
• Records management and documentation

A determination of audit types will be based on requirements defined within the safety management system. Factors relevant to the audits may involve the level of maturity of the SMS, policy initiatives and implementation, and similar issues. The knowledge and understanding of key stakeholders within the organization and Further organizational factors (e.g. number of sites, geographical locations, State, national or international application) may also apply.

Check Out: Slip, Trip, and Fall Audit

Schedule considerations

Having identified the types of internal audit activity to be conducted, the organization will need to consider the most suitable audit delivery options and scheduling. Best practice is a standardized, thorough and transparent methodology which provides clearly defined outcomes to compliment an organization’s business goals and objectives.

These considerations will include one or more of the following points:

• Mandatory audit requirements (e.g. Defined by statutory authority) – These very useful audit areas may include self-insurers annual requirements for audit activity to be conducted for inclusion in reporting requirements. The internal audit in these cases can also act as “radar” for management, ensuring compliance issues are under proper scrutiny.
• Size of organization and geographical locations – Consideration should be given to the different types of activities (and risk potential) within an organization, similarity of activities at different locations to evaluate uniformity of application, geographical locations that may impact on audit schedule delivery. This approach additionally allows for targeting of areas related directly to policy implementation.
• Identified high risk potential subject areas – These areas naturally have high priority in an SMS. Any high-risk areas identified because of statistical analysis or management review require audit verification to assist in implementing strategic management.
• Changes in legislation or organizational structure – Changes in legislation or organizational structure that may impact on the capacity to implement safety requirements. (Note: Legislative changes usually include a time frame for compliance and may involve significant modifications to the SMS. It’s strongly advised that all compliance issues are included in the audit to ensure management has adequate information regarding these matters.)
• Resource base from which the organization can allocate qualified and competent auditors to conduct the audit verification activity type – Requirements of the provision of internal or external resources depending on scope of activity to meet audit needs. The resource base must be able to deliver the necessary standard of auditing to ensure SMS efficiency and compliance.
• Organizational planning and development cycles – Planning of audits to align provision of audit reports with review cycles. This planning is a particularly useful management tool which can ensure proper control and timeliness of operational data. The forward planning also ensures well integrated SMS reporting.
• Prioritized activities (e.g. Based on risk evaluation or business need) – which will impact on implementation of safety requirements.

Check Out: Conduct Your Own Mock OSHA Inspection

Internal Audit schedule detail

The internal audit schedule should be owned by a person who has authority to manage and review the implementation of the schedule. Senior management should have direct oversight of the process, to allow checks on audit functions and efficiency.

The internal audit schedule will provide, as a minimum the following information:

• The type of audit to be conducted
• The expected timeframe in which the audit is to be conducted
• The lead auditor responsible for the audit activity
• Location of the audit
• Timeframe for final report

Common Problems Faced During Internal Audits

One major issue in relation to developing internal audit schedules is that they either do not meet organizational needs and/or merely aim to achieve a level of conformance with statutory body requirements of regulators.

This is quite inadequate and may expose organizations to serious liabilities. To ensure a fully functional SMS which can deal with all safety issues and meets the standards of both statutes and major legal claims, the organization must ensure that the internal audit is conducted on a holistic, best practice, basis in which all areas of liability, risk management and safety are properly audited. The SMS must achieve full coverage of all potential liabilities.

Conversely, the needs of internal audits may exceed the capacity of the organization to meet the requirements defined therein. The organization may lack the expertise required to deal with some areas of risk management. Any internal audit carried out on this basis will inevitably be inadequate and can create a risk of serious deficiencies in the SMS.

Another key problem is to ensure that audit competency (either internal or external) is at a level to achieve a suitable outcome as defined within the internal audit schedule, e.g. There are serious risks in using auditors to conduct compliance audits without the necessary understanding in relation to legislative application of requirements.

It is essential that any audit of an SMS is conducted by auditors having:

• The correct level of audit experience
• Comprehensive experience in statutory compliance, including both self-insurance regulatory requirements and any other relevant statutory issues
• A strong knowledge base and resources, including relevant industry knowledge where applicable
• Proper accreditation for the audit operations required

The safest approach to these issues is to obtain professional guidance. The best SMS consultants can meet all these criteria and can also provide ongoing support and services as required.

Internal marketing is one of the most complicated forms of marketing there is. Internal marketing is when a business markets its products, services and brand to its own employees. Instead of “selling” to consumers (external marketing), the business sells to its employees, treating them like internal consumers — which they are. The best way to conduct internal marketing in an effective way is to create a comprehensive plan.

Internal marketing is important because, firstly, it leads to more employee engagement. It’s one thing for an employee to work for your company in exchange for a paycheck, but another for them to truly believe in your company and what it does. When the latter is the case, employees are motivated to work harder and their loyalty to the company increases.

Developing an internal marketing plan for the launch your new safety policy requires time and effort. It is not something that can be done without planning and proper preparation. Few safety professionals truly understand what they need to do in order to develop an internal marketing plan that will succeed.
Following are five simple steps that can help safety professionals develop effective plans that will work consistently over time. Taking the time to complete these steps can be the deciding factor between success and failure.

5 Steps to Internal Marketing

1) Assemble the right team for the job: Internal marketing doesn’t happen on its own. It often falls solely into the hands of the department launching the new internal policy/program/initiative, but this is a mistake. Often times business professionals know how to inform employees of what’s going on with the company, but don’t have the necessary skills for marketing initiatives. The intent must be to sell, not tell.

Choose one or more of your marketing employees, to work with your department on the internal marketing project. Make sure whoever’s chosen knows how to sell rather than tell, but most importantly, ensure they know the brand inside and out. It may end up being you, the business leader, or other members of upper management who take on the project. If it’s other employees, you may need to give them a lot of direction and guidance. However you do it, get everyone on the same page before moving forward.

2) Assess other department’s current internal marketing: In order to properly strategize your internal marketing, it’s wise to first assess where other departments currently stand. You can then formulate your strategy according to what others are doing well, poorly or not at all, which will make your campaign more targeted and informed.

3) Leaders need to define their goals: Without goals there is no way to determine if marketing efforts are successful or not, internal or external. Determine how you will reach this goal. Set metrics that help measure the success of the strategy. For example, if you intend to decrease injuries by 10 percent by the end of the year, be sure to keep track of where the team is in terms of meeting this goal. Ensure the goals are attainable and reward employees when they are met.

4) Determine a budget: How much money is available to dedicate to your department’s internal marketing efforts will be a large factor in determining what can and cannot be done. Don’t worry if there are little to no funds available to support your marketing efforts. Developing an idea sheet along with approximate costs for each activity during the research process is a great way to keep track of your potential expenses.

Check Out: Budgeting for Training

5) Create materials: Now that you have your internal marketing plan outlined, it’s time to turn it into concrete materials that you can communicate to your team. Mitchell recommends using your team’s everyday experiences at work, like checking email or attending meetings. That way they’re immersed in the brand, making it harder to tune out.
Some ideas:

• Internal newsletter: Create a newsletter to circulate only to your team. Use it to educate them on your brand, products, services, values, goals, etc. Make it interesting by including sections like history, trivia, interesting facts, quotes, images or video.
• In-person meetings: This one may be a little oldschool, but if you regularly conduct meetings and find that they’re successful, call a meeting to discuss the new internal branding effort. Be sure to allow time for questions and discussion.
• Video: Create an internal infomercial that conveys the campaign’s major points. There’s no better platform for merging audio, imagery and text all in one place.
• Signs/Posters: Provide a constant visual message reminder with great graphics to be displayed around the workplace.
• Digital signage: Display internal branding materials like graphics or video on digital screens throughout the office.

Whatever platform(s) you choose, make sure the content is highly personalized. You want your employees to feel individually valued, which leads to more feelings of engagement.

Implementing these steps fosters a culture where employees not only work for the company but genuinely believe in its mission. Employee engagement increases, translating to heightened motivation and loyalty. Moreover, these engaged employees become powerful advocates for the brand, conveying the company’s message authentically.

Check Out: Corporate Volunteering Leads to Engaged Employees

In conclusion, internal marketing, particularly when strategized effectively, plays a pivotal role in cultivating a workplace where employees are not only aware of the company’s goals, products, and services but are deeply engaged and aligned with its mission. This engagement bridges the gap in effectiveness with customers and prospects, making internal marketing a cornerstone for the success of the company brand.