Internal Company OSHA Enforcement & Accountability
This is one of the most critical elements of your OSHA compliance program, because failure to do so seriously undermines and compromises your other compliance efforts. This may sound like a stretch, but it’s true. Refer back to OSHA’s dictum noted at the beginning of this document, which states that every employer is required by law to “Provide a Safe & Health Workplace.” You can literally have “all of the compliance boxes checked,” but if your company fails 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 these workers.
So how can you enforce your health and safety policies to meet this standard? Here are some basic guidelines:
- Train your employees, document all training and retain those records.
- Provide all necessary personal protective equipment (PPE) and demand its use by your employees.
- When employees fail to follow policy, such as not wearing safety glasses or failing to follow LOTO procedures, then implement graduated accountability:
o Verbal warning for first or second time offenses
o Written warnings for additional offenses
o Penalties/Punishment for continued offenses such as docked hours, or even termination of employment.
- Be CONSISTENT with these procedures so your employees get the clear message.
We understand how difficult and challenging it can be to enforce these rules, and how damaging it can be to lose valuable employees, but following these guidelines is your company’s only plausible defense to potential OSHA citations, and even civil or criminal liability if an employee is seriously injured or killed. Employers have the right to claim employee “misconduct” in these cases, but only if consistent accountability & training records can be documented.
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