What’s in Your Safety Program?

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Accidents and injuries are a risk for all businesses, and everyone can agree that good businesses should protect their employees from foreseeable safety and health hazards. To wit, this is enshrined as a general expectation for all U.S. employers. Section 5(a)(1) of the Occupational Safety and Health Act (called the “general duty clause”) requires employers to provide workplaces that are free of recognized hazards, and the requirements for California employers are more explicit. Cal/OSHA regulations (title 8 of the California Code of Regulations, Section 3203 – 8 CCR 3203) require employers to establish, implement and maintain an effective “illness and injury prevention program” (IIPP). So why do I have to have a Written Safety Plan? For California businesses, whether big or small, developing an IIPP is a requirement, but a formal safety program makes sense for all businesses, too. For example, companies may adopt voluntary safety plans to increase worker productivity, prepare for special emergencies and enhance workplace security in addition to simply reducing/preventing injuries and illnesses. In addition, a worker injury or accident will cost businesses money. For every dollar spent on employee injuries or illnesses, businesses spend more on associated costs such as lost production time for both the employee and the supervisors, operations interrupted by the accident, etc. The California IIPP has 8 elements that align closely with professional guidance for effective safety programs. These elements are Responsibility, Compliance, Communication, Hazard Assessment, Accident/Exposure Investigation, Hazard Correction, Training, and Instruction and Recordkeeping. All California employers must establish a safety plan consistent with the Cal/OSHA requirements, but an even more robust safety plan is a good business decision for all employers. What other written safety plans should I have besides having an IIPP? In addition to the general safety programs, OSHA (and Cal/OSHA) require written safety plans for more than two dozen specific general or construction activities and more than a dozen chemicals listed under Subpart Z of the general industry rules for Toxic and Hazardous Substances, such as asbestos, lead and benzene. Some activities or safety programs for which OSHA and Cal/OSHA require a written safety plan include:
  • Hazard Communication (T8 §5194, 29 CFR 1910.1200(e)) plan for facilities where workers could be exposed to hazardous chemicals. Failure to have a written hazard communication plan is a very frequently cited OSHA violation.
  • Emergency Action Plan and Fire Prevention Plan (T 8 §3220., 29 CFR 1910.38 and 29 CFR 1910.39).
  • Bloodborne Pathogens Exposure Control Plan (T8 § 5193., 29 CFR 1910.1030(c)) at facilities that anticipate employee exposure to blood or other potentially infectious materials.
  • HAZWOPER Safety and Health Plan (T8 § 5192, 29 CFR 1910.120(b)) for facilities conducting “emergency response” activities.
  • Respiratory protection (T 8 §5144, 29 CFR 1910.134(c)) for workplaces where employees are required to use respirators.
  • Hazardous energy control (lockout/tagout) (T8 §3314, 29 CFR 1910.147(c)) program to prevent injuries during equipment service and maintenance.
  • Permit-required confined space plan (T8 §5157, 29 CFR 1910.146(c)(4)) for any facility that allows entry to permit-required confined spaces.
Think about how you manage workplace safety and health. There are probably as many different types of safety and health programs as there are businesses. If you manage just a few employees in a low-risk industry, your program is likely to be a simple one: just being a careful observer, listening to your employees’ concerns and responding to them. As businesses grow and become more complex, so do their safety and health programs. The important thing is to identify applicable workplace hazards, evaluate the severity and likelihood of those hazards and then implement effective controls. Control measures include engineering, administrative and personal protective equipment protocols. Programs to address workplace hazards should be documented and evaluated periodically. At a minimum, they must meet applicable regulatory requirements. Regardless of who you are – a small business owner, a division manager or supervisor on the shop floor – your role in managing workplace safety and health is an important one. Do you have any questions about workplace safety requirements, or any other EH&S issues? Contact ACTenviro.... References: https://www.dir.ca.gov/title8index/T8index.asp https://www.osha.gov/laws-regs/regulations/standardnumber/1910 https://www.osha.gov/laws-regs/regulations/standardnumber/1926 – brought to you by the ACTenviro consulting team – your EH&S compliance experts

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