Safety School: Exactly How Does a Safety Manual Protect Your Company In an Inspection?
Too often companies are told that they need to have a custom safety manual to protect them from OSHA violations, and while that’s true, understanding how that works is just as informative to a safely run company as having all the right words and regulations in a policy.
During an inspection, the inspector will ask for the written safety policy and all documentation of training, inspections and discipline. This documentation becomes important after the inspection, when a company can challenge or attempt to mitigate any possible penalties.
In legal terms you have “negating defenses” and “affirmative defenses” to argue any possible citations. The negating defense is simply arguing that that an allegation wasn’t a violation or it didn’t happen. More interestingly there is an affirmative defense, which admits the violation occurred but provides a justification. In a criminal case, “self-defense” is an affirmative defense.
So if an employee is spotted performing an unsafe action and a violation has been assessed, the inspector can look at the safety manual and training documents and ask:
- Is there is a system in place?
- Are employees trained in it?
- Do you inspect the worksite and enforce the policy?
As an example, if the inspector cites an employer for a worker not wearing a hard hat, the company can challenge it with a policy stating that all employees must wear hard hats, evidence that employees are trained to know it’s a requirement, and evidence of inspections to enforce the policy with discipline when an employee doesn’t follow it.
Just having the policy isn’t enough; it needs to be backed up with ongoing application and training.
Safety Key Performance Indicators (KPI)
To go a step further, another way to demonstrate a commitment to safety in your policy is to track it.
Every company has its Key Performance Indicators (KPI). An easy way to know if a company prioritizes safety is to see if they track any safety KPIs such as:
- Days since last incident
- Number of regulatory violations
- Annual change in percentage of training compliance
- Annual change in the Total Case Incidence Rate (TCIR)
A company’s safety performance is the same as any other metric. Have you heard the saying,” what gets tracked is what gets done”?
When you track these safety KPIs, this information can be used in annual safety policy reviews of your manual. Use this information to see if there are incidents or close calls being repeated, or if the current manual and policies cause different hazards not planned for, or if there is something that changed in the last year that needs its own safe work practices.
Other Safety School articles that examine the more academic concepts of occupational safety:
- OSHA Inspections
- Contact Release Training for NFPA 70E 2015
- Scaffolding Code of Safe Practices
- Emergency Response Plans for Permit Required Confined Spaces
- Spotlighting the Importance of Checklists
- Details of a Fully Developed Emergency Action Plan
- The Six Guiding Principles of an Industrial Hygienist
- Exactly How Does A Safety Manual Protect Your Company in an Inspection?
- Who Is Covered (Or Not) By OSHA
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