OSHA mandates that all Texas companies, who fall under their jurisdiction, manage applicable OSHA “Standards” or face severe fines and penalties.
This blog is a quick summary of OSHA Standard requirements, with a deeper dive into Administrative requirements…
Think of Standards as consisting of 6 major components that all employers must address and manage on an ongoing basis. There are other components, but these are the basics. They include:
- Administrative Requirements
- Employee Training
- Health/Exposure Testing
- Identifying and Abating Physical Hazards
- Internal Enforcement & Accountability
These include a company’s written policies and procedures, including the company’s health and safety manual, hazard assessments, etc.
Many companies make the mistake of drafting, or downloading a generic Health & Safety Manual and/or policies from the internet, or from their insurance company, sign it and then put it up on the shelf and then mistakenly believe that they’re now “in compliance.” Nothing could be further from the truth, and here’s why: First of all, your company’s health and safety manual must be customized to address the specific hazards that actually exist at your company. In other words, the manual must include all of the corresponding OSHA Standards, and/or policies and procedures, that will allow your company to manage each of these specific hazards. Having too few standards means that you’ve missed something, and having too many means that you’ve signed yourself up to manage things that have nothing to do with your operations. Your company must conduct a detailed assessment of your operational hazards and create a customized manual that addresses all applicable hazards! Another issue with the generic safety program is the key “company unique” sections the company has to include. These sections can include a Confined Space inventory, specific Lockout/Tagout procedures, chemical listings, unique emergency response plans, etc. These are routinely overlooked and are the second leading cause of program violations, other than not having a written program.
The other major challenge is the fact that each of the OSHA Standards contains elements that the employer must actually DO and MANAGE on an ongoing basis. Examples include employee training, record keeping requirements, routine inspections, drafting & using equipment specific Lockout/Tagout procedures, and developing Hazard Assessments for each job task in your plant. There are many other elements, but these are some of the big ones that manufacturers often miss.
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