(Thanks from coming over from my LinkedIn post….)
To be fair, at that time the wind energy industry was just beginning to gain real traction in the US so even OSHA wasn’t fully aware of the array of hazards, nor had they developed any special guidance, standards or consultation options for the industry. Had I Googled “wind turbine technician OSHA requirements” at that time, I wouldn’t have found any help on the OSHA website nor anywhere else. On the flip side, any good safety professional would have known that many of OSHA’s long established standards applied to the wind industry. Had I been aware of and understood those existing standards at the time, I would have known that my initial “boot camp” efforts fell well short of the law and that there was much more work to be done. Moreover, that the “work” surrounding safety & OSHA compliance never really ends. It’s an ongoing & often complicated process that includes things like customized written policies and procedures, continuous employee training, routine inspections followed by implementation of corrective actions, development of equipment specific Lockout/Tagout procedures, accident investigations followed by root cause analysis, record keeping requirements and on and on and on….
Given my own experiences, it’s not surprising to learn that I’m not alone in having made these false assumptions and mistakes. These days, I often meet with small companies and ask how they “manage safety,” and routinely get answers like “ya, we got our guys OSHA 10 hour training last year,” or “all our forklift drivers got trained and have licences.” But when I follow up by asking, “but what else are you doing to manage safety?,” I’m often met with blank or incredulous looks as if to say, “what else is there?.” One manager at a machine shop once told me, in response to this line of questioning, “we give our guys safety glasses and ear plugs” and actually believed that this was all that was required in order to meet their safety program obligations. True story.
As you can see, the degree of misunderstanding can vary widely, but the common underlying theme is undeniable: many small companies have the false impression that OSHA compliance requirements can be easily “wrapped up” and handled with minimal time, effort and cost. Getting your employees OSHA 10 hour or forklift trained, providing them basic PPE, or in my case sending them to a 3 day safety “boot camp,” are good practices, but are just the “tip of the ice berg” when it comes to managing OSHA compliance.