Are Your Policies Holding You Back? Or Are They Driving Better Safety Performance?

Safety and health policies that reflect commitment, define expectations, and articulate consequences can make a difference in protecting workers. How and what it takes to make that happen are subjects of this Compliance Report. Check out proven best practices from a consultant and a corporate safety director. And find out why a former head of OSHA believes the safety and health policy manual might be going the way of the public pay phone.

Definitions and Expectations

Simply defined, an occupational safety and health policy is a plan that details how an organization will manage OSH issues. A good policy is one that establishes commitment to managing risks and meeting legal duties. And it should guide actions by stating principles and rules. According to the Canadian Center for Occupational Health and Safety, a federal government agency, safety policy should:

• Involve senior management and representatives in its preparation.
• Be consistent with workplace objectives of operating in an efficient and predictable manner.
• Be relevant to a company’s needs, not adopted from another workplace.
• Be considered as important as other workplace policy objectives.
• Address the commitment of senior management to the establishment of a safe and healthy workplace and to the integration of worker protection into all activities.
• Address the intention to treat regulations as a minimum.
• Address the roles and accountability of personnel at all levels.
• Include regular reviews of the policy and ways to monitor its effectiveness. The very best policy is of little value unless it is communicated across the organization. Strategies to do that can include:
• New-hire orientation,
• Policy and procedure manuals,
• Company intranet,
• Safety and health committees,
• Job descriptions and job hazard analyses, and
• Safety talks and meetings at all levels.

Do You Have These?

Roslyn Stone is chief operating officer of Corporate Wellness, Inc. The business, based in Mt. Kisco, New York, acts as an internal medical department for fast-growing, mid-size companies. Corporate Wellness is especially active among restaurants, but also serves green industries, service businesses, and health care. “There are certain key policies that every company needs to have,” Stone explains. Examples are those that address OSHA-mandated programs like bloodborne pathogens, lockout/tagout, confined spaces, electrical safety, and hazard communication. Beyond these, Stone also advises clients to develop policies that reflect employees’ understanding of their safety- and health-related obligations. The first is a healthy working policy. It might require, for example, that an employee out for 3 days or longer needs to bring a doctor’s note upon returning to work. It would also address an employee’s duty to report to a manager if he or she has a communicable disease (these should be listed), and underscore an employee’s duty not to come to work when sick. Stone also recommends a safe working policy. This would state that an employee recognizes his or her duty to follow established safety procedures, report hazards, and tell supervisors if other workers are not using safe practices. As well, Stone believes that all organizations need a drug-free workplace policy. “Without it,” she says, “you will automatically attract the people who have left companies that do have these policies.” A meaningful policy should clearly state the results of using drugs both inside and outside the workplace. Consequences will necessarily differ depending on the type of employment. For example, a business that employs transportation employees or others in safety-sensitive positions might have zero tolerance for workplace drug use. Another employer might provide for assessment and treatment if a worker is discovered using illegal drugs. In Stone’s experience, about 25 percent of employers terminate for any kind of drug-related offense, regardless of where it occurs. Others have a one-strike rule for an off-the-job incident. That means a first offense is tolerated but a second would result in job loss.

Are You Doing This?

Stone offers additional best practices for creating effective policies.

• Integrate policies into operations by involving employees in creating them. Policy should reflect the reality of what employees are doing and are exposed to, not just the beliefs of top management.
• Make sure orientation is not the only time employees are exposed to policies and procedures. Conduct an annual refresher of all policies, even if it’s not mandated by OSHA or another regulator. This is especially important if policies are primarily maintained online and your workforce does not have regular computer access.
• Consider establishing a policy to address emerging threats, such as H1N1 flu or others.

Commitment, Culture Push Policy

At Simmons Bedding Company, safety and health policy drives a robust worker-protection process. But it’s the commitment and culture  behind the policies that really make things happen, explains Jonathan Dawe. He directs safety, health, wellness, and workers’ compensation at the Atlanta-based business. The company employs about 3,000 in the United States and 750 in Canada. “We have four key results areas. In priority order they are safety, quality, service, and cost. All business decisions are made through that lens.” Dawe adds that safety is planned, budgeted, and measured, like any other management system at the 139-year-old company. “We believe that accidents don’t just happen— they’re caused by a combination of unsafe acts and unsafe conditions. And because they have these identifiable causes, they can be prevented.” A companywide internal safety audit process measures performance. The audit is based on a 55-page document that goes well beyond OSHA requirements. Every Simmons facility is graded A to F using the same yardstick, says Dawe. A review of policies and procedures and how they’re being implemented is an important part of that process. Simmons has written OSH policies for accident investigation, hearing conservation, emergency evacuation, safety incentives and recognition, return-to-work, hazard reporting, bloodborne pathogens, forklift operation and training, first aid and CPR, and hot work, among others. There’s also a policy around the mattress maker’s “safety sign-off” program. This ensures that no new machinery, tool, chemical, or process can be installed in any facility without a sign-off from the corporate safety department. Says Dawe, “No purchase order gets processed without a full safety review for any new hazard that employees would be exposed to.” Dawe and his colleagues frequently travel to sites where equipment is being manufactured to make sure company and OSHA safety standards are being met. There’s even a policy for reviewing policy. This is done through corporate and plant-level safety committees on an ongoing basis. All policies are stored electronically on the company intranet and copies are kept in the office of every human resources manager. Each policy states not only what is expected, but also the specific roles and responsibilities of employees at all levels.

Birth of a Policy

Dawe described how new policies are developed at Simmons. He used the example of an arc flash project that was undertaken to ensure that the company’s electrical safe work practices were in compliance with new OSHA regulations. In other instances, policy changes can result from employee suggestions or recommendations from OSHA consultants. (All Simmons plants are involved with OSHA consultation and benefit from regular hazard assessments.) Dawe says a new policy was created midway through the overall arc flash project, which also included developing a hazard-specific program. A group of individuals selected to lead the effort gathered information and got up to speed on the topic. Then a project plan and projected budget were developed. The project team worked with an electrical safety contractor to help with steps that included arc flash assessment, labeling, training, PPE, review of work practice controls, and identifying needed corrective actions. Once the policy was developed and reviewed, it was widely communicated through the safety committee, special plant meetings, and sessions with executive leadership to make sure they were aware and onboard.

OSHA Recommends…

In its handbook for small businesses, OSHA recommends a general safety and health policy be posted near the required OSHA poster. The agency suggests sample language you may wish to adapt to your risks and employees.

1. All employees of this firm shall follow these safe practice rules, render every possible aid to safe operations, and report all unsafe conditions or practices to the supervisor/employer.
2. Supervisors shall insist that employees observe and obey every rule, regulation, and order necessary to the safe conduct of the work and take such action necessary to obtain compliance.
3. All employees shall be given frequent accident prevention instructions. Instructions, practice drills, and articles concerning workplace safety and health shall be given at least once every _____ working days.
4. Anyone known to be under the influence of alcohol and/or drugs shall not be allowed on the job while in that condition. Persons with symptoms of alcohol and/or drug abuse are encouraged to discuss personal or work-related problems with the supervisor/employer.
5. No one shall knowingly be permitted or required to work while his or her ability or alertness is impaired by fatigue, illness, or other causes that might expose the individual or others to injury.
6. Employees should be alert to see that all guards and other protective devices are in proper places and adjusted, and they shall report deficiencies. Approved protective equipment shall be worn in specified work areas.
7. Horseplay, scuffling, and other acts that tend to endanger the safety or well-being of employees are prohibited.
8. Work shall be well-planned and supervised to prevent injuries when working with equipment and handling heavy materials. When lifting heavy objects, employees should bend their knees and use the large muscles of the legs instead of the smaller muscles of the back. Back injuries are the most frequent and often the most persistent and painful type of workplace injury.
9. Workers shall not handle or tamper with any electrical equipment, machinery, or air or water lines in a manner not within the scope of their duties, unless they have received instructions from their supervisor/employer.
10. All injuries shall be reported promptly to the supervisor/employer so that arrangements can be made for medical and/or first aid treatment. First aid materials are located in ____________; emergency, fire, ambulance, rescue squad, and doctors’ telephone numbers are located ___________; and fire extinguishers are located at ___________.