Our OSHA-Safety Program 5 Step Checklist

Welcome and thanks for checking out this blog post.

This cheat sheet will outline the 5 basic steps you’ll need to take to achieve OSHA compliance.

When you’re ready to start building your OSHA compliance program, keep this guide close by and check each step off as you go.

Let’s break them down, shall we?

Step 1:  Conduct a Workplace Assessment

The first step in building a safety program is to conduct an assessment of your workplace to identify all of the health and safety hazards that exist.  These hazards pose a serious risk to your employees and contractors so it’s vital that you identify them during this assessment.

What are safety and health hazards?

• Safety hazards: workplace hazards which create an imminent risk to your employees. Here are some examples:
  • Falls from unprotected heights
  • Exposed pinch or cut points on machinery
  • Burns from corrosive chemicals
  • Broken ladders
  • And many more…
• Health hazards: workplace hazards which create long term health risks such as hearing loss, respiratory illness or even death. Here are some examples:
  • Long and short term exposure to high noise areas
  • Exposure to toxic chemicals or substances

The assessment is a two part process including 1) a physical inspection and 2) review of documents and records.

Part 1: Conduct a physical inspection of your facility, projects and/or field operations to identify all of the health and safety hazards that exist.  Keep in mind that it’s impossible to capture everything in a single inspection, so you’ll have to conduct several inspections over a period of time in order to identify everything.

Part 2:  Conduct a detailed review of all applicable documents and records including all chemical safety data sheets, work instructions and procedures, health exposure test data, and more.  The goal is to identify “hidden” health and safety hazards that could be missed during the physical inspection or those that exist “within” chemicals (for example toxicity, corrosion, etc.)

Make sure to document all of your assessment findings with photos and comments, along with planned corrective actions.  Keep in mind that it’s always a best to correct as many hazards as possible as you work your way through the process.  For example, if you find a broken ladder, then immediately throw it away and replace it with a new one.  Or if you find an exposed pinch point on a piece of equipment, then affix a machine guard to cover it.  As you implement these corrective actions, make sure to track and document them.

Step 2:  Determine which OSHA “Standards” will apply to your company’s safety program

The results of your assessment, especially the identified health and safety hazards, will determine which OSHA standards will apply to your safety program.

What are OSHA Standards? Health & safety rules/laws that describe the methods that employers must use to protect their employees from harm caused by hazards.

Here are some of the most common OSHA standards and what they address:

• Hazard Communication: Hazardous Chemical safety
• PPE: How to choose & use personal protective equipment
• Lockout/Tagout: Control of the accidental release of hazardous energy during equipment maintenance & servicing
• Emergency Action Plan: How to respond to an emergency, like fires, tornadoes, chemical spills, etc.
• Hearing Conservation: How to protect employees from exposure to excessive & loud noise
• Confined Spaces: How to protect employees when entering spaces not intended for human occupation
• Powered Industrial Trucks: Forklift and other powered material handling equipment safety.
• There are many more….

Let’s briefly discuss how to determine which OSHA standards will apply to your safety program.  In summary, your company specific health & safety hazards will “trigger” applicable OSHA standards.  Here are some examples:

• If your assessment identifies hazardous chemicals in your workplace, then the Hazard Communication standard applies.
• If your assessment identifies excessive noise that can’t be eliminated, then the Hearing Conservation standard applies.
• If your company operates forklifts, then the Powered Industrial Trucks standard will apply.

Step 3:  Implement applicable OSHA Standards into your safety program & business operations

It’s not enough to determine which standards apply, you must then implement them into your safety program and regular business operations. In other words, each OSHA standard contains “aspects” that must actually be implemented and then managed on an ongoing basis.

Here are the most common OSHA Standard management “aspects”:

• Written Program: Each standard requires the development of a “written program” which meets the requirements of the standard.  It’s important to understand that these written programs must be customized to address your company specific hazards. In other words, “generic” written programs or “safety manuals” don’t meet the standard.
• Employee training: Nearly all standards include an employee training requirement.
• Procedure development: Many standards include a requirement to develop customized procedures.  For example, individual “Lockout/Tagout” procedures must be developed for each piece of energized equipment which falls under this standard (ie: equipment with multiple energy sources).
• Program audits, reviews & updates: Employers must review each standard, at least annually, to ensure that they remain current.  For example, OSHA’s Hazard Communication standard underwent a major update in 2012 called “GHS” (Globally Harmonized System). To this day, we routinely work with companies who never updated their Hazcom program to reflect these major updates.
• Testing: OSHA’s Respiratory Protection & Hearing Conservation standards require initial “baseline” testing and ongoing surveillance testing to ensure that employees aren’t being negatively impacted by related health exposures.

Step 4: Build & implement a customized employee health and safety training plan

Employee training is one of the most important, yet challenging, components of your safety program.  As mentioned above, each applicable OSHA standard includes training aspects, so now it’s time to create a plan to ensure that your new safety program meets all requirements.

Here are key considerations when developing your customized training program:

• Include a training module for each OSHA standard. This training must cover 2 areas:
  • The “generic” content required for each OSHA standard
  • “Customized” content to address your company specific health and safety hazards. For example, your Hazard Communication training must include information on all of the hazardous chemicals used in your facility
• Create a “training matrix” to include all OSHA standard topics that need to be trained, cross referenced against each department or employee who needs to be trained on each topic. This should be treated as a “living document” and updated regularly.
• How are you going to develop & deliver the training?
  • If you are going to conduct “live” training, your trainer must be very experienced and knowledgeable regarding OSHA standards.
  • If you are going to use “online” or “video” training, that’s fine for the “generic’ content, however you still must develop customized content to address your company specific hazards
• Create a training schedule: The scheduling and delivery of safety training is one of the biggest challenges your new safety program will face.  It’s disruptive and costly to pull employees off the production line to allow for training, but it’s a mandatory and critical part of maintaining OSHA compliance.  Here are some key considerations:
  • We recommend conducting routine, at least monthly, training in order to “keep safety top of mind.” Conducting annual training isn’t an effective practice.
  • Most OSHA standard training topics take 30-60 minutes to adequately train, so make sure to allow enough time.
  • Some OSHA standards have an annual training requirement, while others do not, however it’s always recommended to re-train all topics every year.
• How are you going to test or evaluate for understanding? OSHA has a requirement that employers evaluate to ensure that employees understand the training.  This includes being able to ask questions and get answers, but it’s always a good idea to test for comprehension.
• How are you going to document training? OSHA also has a requirement for “certifying” all employee training.  This can be as simple as having all attendees sign a sheet that lists the date and training topic, but be sure to keep these training records on file.
• Never forget that you must train all new employees before putting them to work. Unfortunately many serious injuries and fatalities occur within the first few hours or days that a new employee goes to work because many are never trained and are therefore unaware of the hazards in their new workplace.

Step 5:  Record Keeping & Reporting

Record keeping & reporting involves workplace injury and illness documentation and tracking and can be broken up into the following 2 areas:

• OSHA 300 logs: These are the logs where you must track and report any “recordable” injuries or illnesses that occur at your company IF you are in a “high hazard” industry and had >10 employees at any time during a calendar year.

Recordable injuries & illnesses are essentially anything that requires more than basic first aid.  The definition is much more detailed, but this is a good general duideline.

You must complete your OSHA 300 logs every year, even if you don’t have any recordable injuries, and then post them for your employees to see from February through                  April every year, and then just about all Manufacturers have to electronically submit their logs to OSHA every year.

• Serious injury & illness reporting: If you have any serious injuries or illnesses that require hospitalization or result in the loss of an eye or amputation, or a fatality, then you must notify OSHA immediately, which of course could trigger an inspection.

Keep in mind that this blog is intended to provide basic guidance for achieving and managing OSHA compliance, but in reality we’ve just scratched the surface.