This critical document often is neglected
Ask someone where a copy of his or her company’s safety manual can be found, and there’s a chance they won’t know. Although a necessary part of a safety program, a safety manual is generally a tool nobody wants to assemble, keep up with, or update.
"Safety in the workplace has become complex, especially keeping up with the dos and don’ts," says Swiki A. Anderson, PhD, PE, president of Accu*Aire Controls in Bryan, TX. Anderson says he and a group of other safety professionals are trying to establish some methods for assembling — and importantly, continually updating — safety programs for the workplace.
The need for a manual that spells out a company’s safety policy is obvious — a safety program is of little use if employees don’t know what it is and cannot refer to it. Experts told Occupational Health Management that some other reasons to have an up-to-date, truly useful written safety program are to:
- promote cooperation, raise morale, and increase productivity;
- increase the employees’ responsibility for workplace safety;
- save money and reduce costs;
- reduce liability for OSHA violations;
- reduce employee absenteeism;
- maintain the company’s reputation.
Why put it in writing?
Though often described as the book everyone’s supposed to be familiar with but isn’t, a company’s safety manual is the center of its comprehensive safety program. According to the Du Pont Resource Guide to Safety Services, safety programs have helped many companies reduce accidents by 50%-70% in as little as two years.
In addition, many states’ labor laws require employers to have, in writing, their company’s safety program.
"You may want to put together a safety manual to give to employees at the time of hiring," says Marvin Newsome, safety officer with the Workers Compensation Board, Northwest Territories and Nunavut, in Canada’s Northwest Territories. "When employees know from their first day that management puts great value on safety, they will be more likely to take precautions when working."
Besides being a good idea, a safety manual — while not required by OSHA — also can serve as a good tool against liability should an accident occur.
Who needs to be involved?
Developing a good manual starts with appointing someone with a broad knowledge of environmental health and safety to talk with those knowledgeable about the company, its operations, its people, and the hazards posed, says Carter Ficklen, CIH industrial hygienist, Mainthia Technologies Inc. and NASA LaRC Safety and Mission Assurance Support in Hampton, VA. "A safety program is not a word document that you buy on the Internet for $49.95, and then hit select/ replace all’ to include your company name."
Most mentioned the importance of getting all levels of employees involved in the development, maintenance, and use of the manual.
The most important resource you will need to initiate or improve your safety program is input from employees, contractors, and subcontractors. Their involvement is critical to the success of the program for several reasons, because it will:
- Increase their sense of ownership in the program. This will result in employee support for the program, which is necessary because many of them work in areas that will be most greatly affected by the safety program. They can offer valuable insight because of their skills and hands-on experience with hazardous work.
- Increase their knowledge of program objectives and requirements.
- Result in a higher level of worker compliance to program requirements.
Obtain employee, contractor, and subcontractor input by informing them of any plans related to the introduction of the safety program, inviting them to participate as often as possible, telling them how their input will be used, and then actually using their input; and giving them the finished products to use. "A manual developed with common sense and practical environmental health and science knowledge, combined with management commitment and worker buy-in and involvement makes a solid program," says Ficklen.
James N. Gotay, QEP, CSP, of Matawan, NJ-based Skyline Environmental Inc., suggests beginning with an audit. "Start with conducting a regulatory audit to identify the site-specific facility needs, then conduct a wrap-up meeting with site management to identify preferences and provide additional input on regulatory requirements," he advises. "A consensus of opinions should lead to a document with management support. Upper management sponsorship of the program will cause the functional staff to take notice."
Gotay says a safety and health manual consisting of generic, nonapplicable programs generated simply to attempt to comply with regulations "is going to sit on the counter and collect dust."
Every business in the United States has to comply with general industry standards that cover things like safety exits, ventilation, hazardous materials, personal protective equipment like goggles and gloves, sanitation, first aid, and fire safety.
Under OSHA, employers have a general duty to "maintain a safe workplace," which covers all situations for which there are published standards. OSHA’s web site provides some tools to help companies start a health and safety program or update an existing one (www.osha.gov/SLTC/safetyhealth/index.html). OSHA and state safety organizations conduct safety consultation programs free of charge.
Experts say an early source to consult is the company’s insurance carrier. Ask if an insurance company safety specialist can visit the site and make recommendations. Insurers typically are happy agree, since the safer the business is, the fewer accident claims they will see.
After employee input, the most important resources are any materials, policies, procedures, or other means the company intends to use to promote safety. The safety manual should highlight and explain the specific dangers and hazards of the company’s environment. To get the most comprehensive view, it should pool safety information from department managers, equipment and tool manufacturers (if applicable), and occupational safety and health experts. The safety manual should include information on startup and lockdown procedures, operational safety procedures, types of activities to avoid at work, and proper attire for operating equipment.
Some experts recommend putting the manual through a final review by an insurance professional, a government representative, and an attorney.
It’s finished . . . now use it
Once the written version of a safety policy has been created, someone within the company should be charged with the responsibility carrying out the program and keeping the manual up to date. There should be a system — ideally, addressed in the manual itself — for ensuring that employees comply with safe and healthful work practices, and which includes disciplinary action as well as recognition of safe work habits.
Along with the manual, there should be put into place (if it doesn’t already exist) a system for:
- communicating with employees about occupational safety and health, including encouragement to inform the employer of worksite hazards without fear of reprisal;
- identifying and evaluating workplace hazards, including scheduled periodic inspections;
- investigating an occupational injury or illness;
- correcting, in a timely manner, unsafe or unhealthful conditions or work practices;
- safety and health training for employees and supervisors;
- documenting scheduled, periodic inspections and employee safety and health training (OSHA requires these records be kept for three years).
"It’s important to make your safety program accessible to everyone affected by the program by distributing copies of your safety program manual to each worksite and by making copies available to anyone who requests one," says Ficklen.
Keeping an up-to-date list of all employees, contractors, and subcontractors holding copies of the safety program materials will make distributing updates easier. Some safety consultants recommend including a page in the manual that employees must sign, date, and return stating they have read and understood all the information in the manual and agree to abide by it.
Keep the manual current
Establishing a safety program and manual is one thing; keeping it current with technology, regulations, and changing facilities is another. Anderson says he and his colleagues have studied various formats, in addition to a traditional print format, for documenting his company’s safety program, but always come back to the question of which is going to be easiest to update on a regular basis. "No matter which format we look at — print, electronic, database — it opens up another can of worms," he admits.
Suggestions for keeping the manual useful and current include a regular review and update of all aspects of the safety program, and simultaneous update of the manual. To ensure that everyone is on the same page, so to speak, experts recommend controlling the revision process from a central location, such as the company’s headquarters, with any proposed changes and additions directed to a specific person at that location.
If a record is kept of all employees and contractors holding copies of the earlier version, use the list to make sure everyone gets a copy of any updates or supplements. Ask anyone receiving an updated copy to destroy to old copy, to avoid confusion.
Additional tips for developing health and safety programs and manuals can be found in Guidelines for Developing Effective Health and Safety Programs, a publication of the Workers Compensation Board, Northwest Territories and Nunavut. It is available on-line at: www.wcb.nt.ca/publications/GuidelinesDeveloping.pdf.
For more information, contact:
• Swiki A. Anderson, PhD, PE, President, Accu*Aire Controls, 1516 Shiloh Ave., Bryan, TX 77803. Phone: (979) 779-6068. E-mail: firstname.lastname@example.org.
• Carter Ficklen, Industrial Hygienist, Mainthia Technologies Inc. and NASA LaRC Safety and Mission Assurance Support, Hampton, VA. Phone: (757) 864-3205. E-mail: email@example.com.
• James N. Gotay, QEP, CSP, President, Skyline Environmental Inc., Matawan, NJ. Phone: (732) 583-2500. E-mail: SKYLINEENV@aol.com.
• Robert A. Nicol, CSO, CRSP, corporate safety director, Albrico Services, Edmonton, Alberta, Canada. Phone: (403) 346-9342. E-mail: firstname.lastname@example.org.