1926 Subpart C - Safety and Health Program Management Guidelines

Effective management of worker safety and health protection is a decisive factor in reducing the extent and severity of work-related injuries and illnesses and related costs. In 1982, OSHA began to approve worksites with exemplary safety and health management programs for participation in Voluntary Protection Programs (VPP). More information on VPP can be obtained from your OSHA Regional or Area Office listed at the end of this publication.

In 1989, OSHA issued recommended guidelines for the effective management and protection of worker safety and health. These guidelines are summarized in the following paragraphs.

General

Employers are advised and encouraged to institute and maintain in their establishments a program that provides adequate systematic policies, procedures, and practices to protect their employees from, and allow them to recognize, job-related safety and health hazards.

An effective program includes provisions for the systematic identification, evaluation, and prevention or control of general workplace hazards, specific job hazards, and potential hazards that may arise from foreseeable conditions.

Although compliance with the law, including specific OSHA standards, is an important objective, an effective program looks beyond specific requirements of law to address all hazards. It will seek to prevent injuries and illnesses, whether or not compliance is at issue.

The extent to which the program is described in writing is less important than how effective it is in practice. As the size of a worksite or the complexity of a hazardous operation increases, however, the need for written guidance increases to ensure clear communication of policies and priorities as well as a consistent and fair application of rules.

Major Elements

An effective occupational safety and health program will include the following four main elements: management commitment and employee involvement, worksite analysis, hazard prevention and control, and safety and health training.

1. Management Commitment and Employee Involvement

The elements of management commitment and employee involvement are complementary and form the core of any occupational safety and health program. Management's commitment provides the motivating force and the resources for organizing and controlling activities within an organization. In an effective program, management regards worker safety and health as a fundamental value of the organization and applies its commitment to safety and health protection with as much vigor to other organizational goals.

Employee involvement provides the means by which workers develop and/or express their own commitment to safety and health protection for themselves and for their fellow workers.

In implementing a safety and health program, there are various ways to provide commitment and support by management and employees. Some recommended actions are described briefly as follows:

• State clearly a worksite policy on safe and healthful work and working conditions, so that all personnel with responsibility at the site (and personnel at other locations with responsibility for the site) fully understand the priority and importance of safety and health protection in the organization.
• Establish and communicate a clear goal for the safety and health program and define objectives for meeting that goal so that all members of the organization understand the results desired and measures planned for achieving them.
• Provide visible top management involvement in implementing the program so that all employees understand that management's commitment is serious.
• Arrange for and encourage employee involvement in the structure and operation of the program and in decisions that affect their safety and health so that they will commit their insight and energy to achieving the safety and health program's goal and objectives.
• Assign and communicate responsibility for all aspects of the program so that managers, supervisors, and employees in all parts of the organization know what performance is expected of them.
• Provide adequate authority and resources to responsible parties so that assigned responsibilities can be met.
• Hold managers, supervisors, and employees accountable for meeting their responsibilities so that essential tasks will be performed.
• Review program operations at least annually to evaluate their success in meeting the goals and objectives so that deficiencies can be identified and the program and/or the objectives can be revised when they do not meet the goal of effective safety and health protection.

2. Worksite Analysis

A practical analysis of the work environment involves a variety of worksite examinations to identify existing hazards and conditions and operations in which changes might occur to create new hazards. Unawareness of a hazard stemming from failure to examine the worksite is a sign that safety and health policies and/or practices are ineffective. Effective management actively analyzes the work and worksite to anticipate and prevent harmful occurrences. The following measures are recommend to identify all existing and potential hazards:

• Conduct comprehensive baseline worksite survey for safety and health and periodic comprehensive update surveys and involve employees in this effort.
• Analyze planned and new facilities, processes, materials, and equipment.
• Perform routine job hazards analyses.
• Assess risk factors of ergonomics applications to workers' tasks.
• Conduct regular site safety and health inspections so that new or previously missed hazards and failures in hazard controls are identified.
• Provide a reliable system for employees to notify management personnel about conditions that appear hazardous and to receive timely and appropriate responses and encourage employees to use the system without fear of reprisal. This system utilizes employee insight and experience in safety and health protection and allows employee concerns to be addressed.
• Investigate accidents and "near miss" incidents so that their causes and means of prevention can be identified.
• Analyze injury and illness trends over time so that patterns with common causes can be identified and prevented.

3. Hazard Prevention and Control

Where feasible, workplace hazards are prevented by effective design of the job site or job. Where it is not feasible to eliminate such hazards, they must be controlled to prevent unsafe and unhealthful exposure. Elimination or control must be accomplished in a timely manner once a hazard or potential hazard is recognize. Specifically, as part of the program, employers should establish procedures to correct or control present or potential hazards in a timely manner. These procedures should include measures such as the following:

• Use engineering techniques where feasible and appropriate.
• Establish, at the earliest time, safe work practices and procedures that are understood and followed by all affected parties. Understanding and compliance are a result of training, positive reinforcement, correction of unsafe performance, and if necessary, enforcement through a clearly communicated disciplinary system.
• Provide personal protective equipment when engineering controls are infeasible.
• Use administrative controls, such as reducing the duration of exposure.
• Maintain the facility and equipment to prevent equipment breakdowns.
• Plan and prepare for emergencies, and conduct training and emergency drills, as needed, to ensure that proper responses to emergencies will be "second nature" for all persons involved.
• Establish a medical program that includes first aid onsite as well as nearby physician and emergency medical care to reduce the risk of any injury or illness that occurs.

4. Safety and Health Training

Training is an essential component of an effective safety and health program. Training helps identify the safety and health responsibilities of both management and employees at the site. Training is often most effective when incorporated into other education or performance requirements and job practices. The complexity of training depends on the size and complexity of the worksite as well as the characteristics of the hazards and potential hazards at the site.

Employee Training

Employee training programs should be designed to ensure that all employees understand and are aware of the hazards to which they may be exposed and the proper methods for avoiding such hazards.

Supervisory Training

Supervisors should be trained to understand the key role they play in job site safety and to enable them to carry out their safety and health responsibilities effectively. Training programs for supervisors should include the following topics:

• Analyze the work under their supervision to anticipate and identify potential hazards.
• Maintain physical protection in their work areas.
• Reinforce employee training on the nature of potential hazards in their work and on needed protective measures through continual performance feedback and, if necessary, through enforcement of safe work practices.
• Understand their safety and health responsibilities.

Source: OSHA

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