Internal Company OSHA Enforcement & Accountability
This is one of the most critical elements of your OSHA compliance program, because failure to consistently enforce your safety program seriously undermines and compromises the entire process.
This may sound like a stretch, but it’s true. Refer to OSHA’s dictum noted on their website which states that every employer is required by law to “Provide a Safe & Health Workplace.”
In other words, your company can literally have “all of the OSHA compliance boxes checked,” but if you fail to manage accountability, you’re essentially allowing your employees to engage in dangerous behavior. This is a clear violation of OSHA’s dictum because it creates a potentially unsafe and unhealthy workplace for your employees.
So how can you enforce your health and safety policies to meet this standard? Here are some basic guidelines:
- It all begins with top-down “management commitment.” In other words, company ownership and leadership must lead with messaging and lead by example. This means always emphasizing a strong safety message, and always demonstrating that support by wearing PPE and following safety rules. If company leadership doesn’t follow the rules, then why would employees?
- Train your employees on all applicable OSHA standards, document all training using sign-in sheets and retain training records.
- Provide all necessary personal protective equipment (PPE) and demand its use by your employees.
- Conduct routine safety inspections to quickly identify and address situations where employees aren’t following the rules.
- When dealing with non-compliance, use an educational approach rather than the “stick” approach. Employees will always appreciate a softer approach to safety compliance, especially when management emphasizes how safety helps to ensure that the employee will return to home each day in a healthy condition.
- When employees fail to follow policy, such as not wearing safety glasses or failing to follow LOTO procedures, for example, then always hold them accountable.
Here is a basic graduated enforcement process:
- Verbal warning for first or second time offenses
- Written warnings for additional offenses
- Penalties/Punishment for continued offenses such as docked hours, or even termination of employment.
- Be CONSISTENT with these procedures so all of your employees get the clear message.
We understand how difficult and challenging it can be to enforce safety rules, and how costly it can be to lose and then replace valuable employees who don’t follow safety rules, but the costs of failing to do so are just to big to ignore. This includes serious injuries, potential fatalities as well as major OSHA fines and penalties if you get inspected.
Also never forget that these guidelines are your company’s only plausible defense to potential OSHA citations, and even civil or criminal liability if an employee is seriously injured or killed on the job.
In other words, employers have the right to claim employee “misconduct” in these cases, and avoid all of these liabilities but only if consistent accountability & training records can be documented.
Enforcement and accountability is a major and vital component of any safety program.
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