Safety, Coaching and Documentation
Recently, our Safety Consultant Ron Humphreys brought to our attention two problematic issues with OSHA compliance he’s seen among some of our clients. We felt it was important insight to share with all our business customers.
“As basic as this is,” Humphreys said, “I’m still surprised how many organizations are unprepared to confront an OSHA inspection and/or investigation!” He pointed out that not being prepared in advance has caused several companies to obtain unnecessary violations, which resulted in additional costs and fines that could have been avoided.
“I suggest to the business owners and managers I work with through The Starr Group Risk Reduction program,” Humphrey advises, “to consider an OSHA encounter as an ‘emergency’ and include it in their OSHA-required Emergency Response Program.”
“It’s not rocket science,” says Humphrey. “Appoint an informed [safety] group of employees to review in advance your company’s safety policies and past safety history.” This group will prove valuable when the need to respond to an OSHA encounter arises. “They’ll be able to quickly steer your company through the process in an effective, less painful manner,” he says.
Additionally, it is suggested that the safety group document any violations and corrective measures taken in the past, along with the subsequent results. The next step should be to assess the current “state of the company” to discover if any weak areas exist in safety protocol. These can be easily addressed without having OSHA involved.
Should OSHA pop in for an inspection, you will have documentation proving that your company has corrective measures in place.
Safety Rule/Policy Enforcement
“Company leadership needs to understand the value of documented safety program enforcement,” Humphreys stressed, “I cannot overstate this.”
OSHA won’t tell businesses when or how to discipline employees, but this is just one aspect of enforcement anyway. However, Humphreys says, “OSHA does say that retraining is necessary in many of their standards if rules are violated or an incident occurs.”
Accordingly, if an employee violates policy, a coaching episode should be made and it should be documented. This effort can be all the difference with an employer confronting a violation —or worse, repeating one— and avoiding it altogether.
Take this point one step further and treat a “violation” similar to an “incident.” Determine the root cause and take corrective measures to avoid a recurrence.
Some supervisors find it difficult to “discipline” an employee. Managers should understand the difference between “coaching” and “discipline”. They need to be versed on their HR policies, so they can consistantly and constructively share them with staff members.
It’s not all that uncommon to find that established company policies are long forgotten by deep-rooted employees or completely unknown by new hires. However, Humphreys points out, “These employees need to know them if they are expected to use them.”
In his travels, Humphreys finds these two topics often are not well defined, and frequently they surface only after an OSHA encounter or a serious injury resulting in an OSHA investigation. We’ve only scratched the surface here. If you would like more information about selecting your “Saftey Group”, keeping proper safety documentation, or training your supervisors in “Coaching” , call The Starr Group today! 414-421-3800