Policies and Processes
Now let’s take a look at safety policies and processes to see how they fit into the CSMS.
Developing CSMS Policies
Safety policies help to set standards and guidelines for decision-making. They let managers, supervisors and employees make safety decisions with some degree of confidence without having to constantly check with “the boss”. Managers, supervisors and workers know they are making decisions that conform to corporate safety policies.
The safety policy is usually stated in three different ways:
- What you intend to do in safety: “It will be our policy to perform safe-construction or no-construction.”
- Who will be involved in safety: “Site supervisors/foreman will be responsible for the safety of workers on their site.”
- How you will control safety: “Lockout/Tagout will be performed for electrical work on 50V circuits or higher.”
Developing CSMS Policies (continued...)
Below are a few more examples of various safety policies that may be important to include:
- No job or task is more important than worker health and safety.
- If a job represents a potential safety or health threat, every effort will be made to plan a safe way to do the task.
- Every procedure will be a safe procedure. Shortcuts in safe procedures by either foremen or workers will not be tolerated.
- If a worker observes any unsafe condition, which may pose a potential threat to their health or safety, it will be expected that employees will immediately correct the situation when feasible or inform management. Management has the responsibility to take adequate precautions, comply with OSHA standards, and assure the Safety of employees.
- If a job cannot be done safely it will not be done.
- Management will provide visible ongoing commitment, resources, and leadership to assure the implementation of the CSMS. All employees should be provided equally high quality safety and health protection.
- Leadership within a company will acknowledge the importance of creating a positive safety culture through employee involvement and effective policies and procedures.
Safety Rules are Just “Mini-Policies”
Rules are nothing more than narrowly-focused policies. They focus on one specific safety behavior or action that is required of each individual employee.
This is an example of a rule.
Rules vs. Guidelines
It’s important to understand the difference between “rules” and “guidelines”. It’s simple: rules are required – guidelines are not.
To be valid, rules include words like “must”, “shall”, or “will”. Remember, rules do not give a person a choice: they are mandatory. By the way, if no word is listed, assume it’s a rule.
Guidelines, on the other hand, do give employees a choice. They contain words like “should”, “recommend” or “may.” It’s very important to know that you can’t really “enforce” guidelines because they are voluntary. If you find that you have guidelines and rules listed together, be sure to define the concepts and separate them so that everyone clearly understands the difference.
I know you’re probably familiar with the safety rules within your company, but, just to make sure, I’ve listed a few of the more common rules generally found at construction sites:
- Keep your work area free from rubbish and debris. A clean job is the start of a safe job.
- Compressed air shall not be used to blow dust or dirt from clothes, hair, or hands.
- Any fear of working at heights must be reported to the immediate supervisor.
- Employees working at height must keep back at least 10’ from all power lines.
- Do not use power tools and equipment until you have been properly instructed in the safe work methods and are formally (in writing) authorized to use them.
- Do not remove a safety device or safeguard on equipment without proper authorization.
- Before servicing, repairing, or adjusting any powered tool or piece of equipment, disconnect it, lock out the source of power, and tag it out. (no word listed, so assume it’s a rule.)
- Excavations more than five feet deep will be shored or sloped as required. Keep out of trenches or cuts that are not properly shored or sloped.
- All workers will use the "four to one" rule when using a ladder. One foot of base for every four feet of height.
- Portable ladders in use shall be equipped with safety feet unless the ladders are tied, blocked or otherwise secured. Step ladders shall not be used as a straight ladder.
Developing CSMS Processes
A process is nothing more than sequence of interdependent and linked procedures. Each CSMS program may include one or more processes used to build residential or commercial buildings, construct highways or to construct dams. The emphasis would be to ensure safe procedures and practices.
Here are some more common processes for building a residential building.
- Worksite inspection
- Accident investigation
- Laying a foundation
- Electrical installation
- Roof construction
- Framing the structure
- Installing HVAC
- Obtaining permits
Let’s discuss a couple of common construction safety processes below.
Accident Investigation Process
All accidents on your worksite resulting in injury or property damage should be investigated. The investigation is a very important process that includes procedures for documenting the accident scene, analyzing the facts, and interviewing witnesses.
The accident investigation process will make sense if you understand that ultimately, the purpose of the investigation is to improve the safety management system. If you conduct the investigation for any other reason, it will likely result in ineffective solutions.
Here are the six basic procedures in conducting accident investigations.
- Secure the accident scene
- Conduct interviews
- Develop the sequence of events
- Conduct cause analysis
- Determine the solutions
- Write the report
Accountability - Disciplinary Process
The implementation of the following four step disciplinary process should be considered when operational and/or safety rules are not followed or other unsafe actions endanger workers.
- First violation: Oral warning; notation for personnel file.
- Second violation: Written warning; copy for file or Personnel Office.
- Third violation: Written warning; one day suspension without pay.
- Fourth violation: Written warning and one-week suspension, or termination if warranted.
There are some violations that are so dangerous to the worker and/or others that they will result in immediate termination if justified. For more information on developing an accountability program that includes an effective disciplinary process, be sure to take Course 700, 702, or 704.
Stage 1: Establish a company disciplinary policy for all employees re: compliance with S&H regulation, rules, procedures, etc.
Stage 2: Continue to implement disciplinary plan with an implementation schedule for managers and employees. Require subcontractors, if applicable, to adopt company disciplinary policy or establish equivalent policies.
Stage 3: Ensure discipline is equally enforced for company and subcontractor employees.
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