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

Crashes are not an unavoidable part of doing business.

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

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

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

Direct costs (insurable)

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

Indirect costs (uninsurable)

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

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

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

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

I published a Fleet Safety Toolbox Talk on amazon, check it out.

Getting started in establishing a World Class Fleet Safety Program

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

Check Out: How to Improve Your Safety Culture

Think about developing a team to work on these steps:

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

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

Bloodborne Pathogen Policy

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

The policy establishes the required contents of the ECP.

Sample Policy

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

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

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

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

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

Program Administration

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

The program administrative section determines who will:

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

Sample Program Administration

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

Check Out: Understanding OSHA Bloodborne Pathogens Standard

Employee Exposure Determination

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

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

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

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

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

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

Sample Employee Exposure Determination

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

Use as many lines as necessary.

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

Job Title / Department – Location / Task – Procedure

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

Use as many lines as necessary.

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

Occupations with a likely chance of occupational exposure include:

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

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

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

Methods of Implementation and Control

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

Topics included in this section of the ECP are:

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

Methods To Control The Risk Of Exposure

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

PPE for Bloodborne Pathogens

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

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

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

Effective PPE

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

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

Employer responsibilities

An employer must ensure employees use appropriate personal protective equipment.

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

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

Sample Methods of Implementation and Control

Universal Precautions

All employees will utilize universal precautions.

Exposure Control Plan

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

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

Engineering Controls and Work Practices

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

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

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

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

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

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

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

Personal Protective Equipment (PPE)

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

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

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

All employees using PPE must observe the following precautions:

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

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

Housekeeping

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

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

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

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

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

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

Laundry

The following contaminated articles will be laundered by this company:

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

The following laundering requirements must be met:

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

Labels

The following labeling methods are used in this facility:

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

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

Read: Understanding OSHA Bloodborne Pathogens Standard

Hepatitis B Vaccination

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

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

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

The hepatitis B immunization series requires three separate injections.

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

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

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

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

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

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

Vaccination is encouraged unless:

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

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

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

Post-Exposure Evaluation and Follow-Up

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

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

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

Sample Post-Exposure Evaluation and Follow-Up

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

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

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

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

Administration of Post-Exposure Evaluation and Follow-Up

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

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

Sample Administration of Post-Exposure Evaluation and Follow-Up

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

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

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

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

Procedures for Evaluating the Circumstances Surrounding an Exposure Incident

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

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

Sample Procedures for Evaluating the Circumstances Surrounding an Exposure Incident

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

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

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

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

Employee Training

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

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

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

Sample Employee Training

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

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

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

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

Recordkeeping

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

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

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

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

Sample Recordkeeping

Training Records

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

The training records include:

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

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

Medical Records

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

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

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

OSHA Recordkeeping

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

Sharps Injury Log

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

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

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

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.

Treatment

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.

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.”

Check out the safety committee books and meeting notes I have available on Amazon

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.

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.

Check Out: Fire Risk Assessment

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.

Check Out: Risk Assessment Guidelines

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.

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!

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:

• Audit for risks in the workplace–
  • Hazards can’t be addressed in the workplace without understanding the risks present. This would include conducting a job hazard analysis so risks can be addressed via the hierarchy of control principle.
• Write safety policies, and related training–
  • Once you have identified the workplace hazards, this is an opportune time to write policies and develop appropriate training to address the risks identified. On top of that, this is an opportune time to ensure you have the common written policies required by OSHA:
    • Hazard Communication Plan
    • Lockout/Tagout Program
    • Respiratory Protection Program
    • Personal Protection Equipment Plan
    • Bloodborne Pathogens & Post Exposure Plan
    • Emergency Action Plan
    • Confined Space Program
    • Electrical Safety Plan
    • Fire Prevention Plan
    • Hearing Conservation Plan
    • Crane/Hoist/Sling Inspection Program
    • Fall Prevention Program
    • First Aide Policy
    • Hot Work Program
    • Spill Response Plan
    • Machine Guarding Policy
• Work on building a safety culture-
  • A safety culture is built from the top down, executives need to embrace workplace safety first, this will show importance to all people in the company. In order for safety to be built into the culture of a company, every operational policy and training will incorporate safety, To learn more about safety culture in the workplace, check out this post.
  • Another part of a strong safety culture is a quality safety team. This means the members are committed to safety, and can provide influence in their work areas. To learn some more about safety committees, check out this post.
• Evaluate–
  • Reviewing and evaluating the company safety program, at least annually, is important. This ensures the programs are still relevant to any changes in operational procedures, or changes in regulations. The evaluation also provides the opportunity to check the effectiveness of the policy, has it lowered risk, has it decreased injuries?

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.