Management Leadership

Worker Participation

Find and Fix Hazards

Recommended Practices for Safety and Health Programs

Occupational Safety and Health Administration osha.gov/safetymanagement OSHA 3885 October 2016

DISCLAIMER These practices for safety and health programs are These recommended practices apply to employers, recommendations only. Employers are not required to except in the construction industry, for whom there have a safety and health program that complies with are separate Recommended Practices for Safety and them and will not be cited for failing to have a safety Health Programs for the Construction Industry. and health program that complies with this document.

FOREWORD

FOREWORD Establishing a safety and health program in your workplace is one of the most effective ways Resources and Tools to Support of protecting your most valuable asset: your Implementation of These workers. Losing workers to injury or illness, even Recommended Practices for a short time, can cause significant disruption and cost—to you as well as the workers and their OSHA has created a dedicated Web page families. It can also damage workplace morale, to support the implementation of these productivity, turnover, and reputation. recommended practices at osha.gov/ safetymanagement. The page includes the Safety and health programs foster a proactive following: approach to “finding and fixing” workplace hazards before they can cause injury or illness. • Additional resources. Articles and Rather than reacting to an incident, management information sources related to each core and workers collaborate to identify and solve element of the recommended practices, issues before they occur. This collaboration builds plus other topics discussed in the trust, enhances communication, and often leads recommended practices. to other business improvements. Employers who • Tools. Downloadable templates, have implemented safety and health programs, worksheets, and reference materials you including many who are in OSHA’s Voluntary can use as you develop your own safety Protection Programs (VPP) or the Safety and and health program. Health Achievement Recognition Program (SHARP) for small and medium-sized businesses, Please visit the recommended practices have also found that managing for safety results Web page and explore the resources in higher-quality product or output and higher available. OSHA will update the Web page profits. and add resources and tools as they become available. Thousands of responsible employers have used OSHA’s 1989 Safety and Health Program Management Guidelines as a blueprint for setting up an effective safety and health program.1 • Automation of work activities means that technology, computers, and robotics are Much has changed, however, since those being integrated into our workplaces, often guidelines were published: introducing new and different hazards.

• The nature of work is evolving as the • An aging workforce and the rise of sedentary economy continues to shift from a work and lifestyle means that some manufacturing to a service base, and from a workers are at higher risk for work-related fixed to an often mobile workforce. musculoskeletal disorders.

1 54 FR 3904–16, January 26, 1989.

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FOREWORD

• There is greater recognition that workers These new recommended practices reflect these in industries that some think of as safe changes. They also reflect what we have learned (such as healthcare, lodging, retail, and from best-in-class programs and what makes transportation) face significant hazards. them effective. In particular, these recommended practices place greater emphasis on involving • Increased temporary and contract workers, and include a more robust program employment, and the rise of the “gig evaluation element to help drive continuous economy” mean that traditional relationships improvement. The recommended practices between workers and employers are shifting, also stress the need for communication and and changes in safety programs and policies coordination on worksites involving more than will be required to ensure the safety of all one employer. workers at worksites characterized by these newer and more fluid relationships. In addition, the new recommended practices build on successful approaches and practices that have evolved under OSHA programs such VPP and SHARP. They also align with national and international consensus standards. 2

2 A comparison of these recommended practices, the 1989 guidelines, OSHA voluntary programs, and other consensus standards is available on the Recommended Practices for Safety and Health Programs website.

ii RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS osha.gov/safetymanagement

CONTENTS INTRODUCTION. .................................................................................................................................................. 2

MANAGEMENT LEADERSHIP........................................................................................................................... 9

WORKER PARTICIPATION. ...............................................................................................................................11

HAZARD IDENTIFICATION AND ASSESSMENT........................................................................................ 15

HAZARD PREVENTION AND CONTROL..................................................................................................... 20

EDUCATION AND TRAINING. ........................................................................................................................ 24

PROGRAM EVALUATION AND IMPROVEMENT. ...................................................................................... 27

COMMUNICATION AND COORDINATION FOR HOST EMPLOYERS, CONTRACTORS, AND STAFFING AGENCIES. ............................................................................................................................ 30

LIST OF ABBREVIATIONS. ............................................................................................................................. 34

GLOSSARY OF TERMS..................................................................................................................................... 34

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INTRODUCTION THESE RECOMMENDED PRACTICES provide service sector, healthcare, retail, and even responsible employers, workers, and worker mobile or office-based work environments. representatives3 with a sound, flexible They also include information specifically aimed framework for addressing safety and health at temporary worker and multiemployer work issues in diverse workplaces. They may be situations. Separate recommended practices are used in any workplace, but will be particularly available for the construction industry. helpful in small and medium-sized workplaces. They can be applied equally well in traditional, fixed manufacturing workplaces and in the

3 Worker participation is vital to the success of the program. In several places in this document, OSHA refers not just to workers but also to their representatives, such as labor unions or religious or community groups.

INTRODUCTION

The recommended practices emphasize a THE BENEFITS OF IMPLEMENTING proactive approach to managing workplace THESE RECOMMENDED PRACTICES safety and health. Traditional approaches are often reactive—that is, actions are taken only Responsible employers know that the main goal after a worker is injured or becomes sick, a of a safety and health program is to prevent new standard or regulation is published, or an workplace injuries, illnesses, and deaths, as well outside inspection finds a problem that must as the suffering and financial hardship these be corrected. Finding and fixing hazards before events can cause for workers, their families, and they cause injury or illness is a far more effective their employers. approach. Doing so avoids the direct and indirect Employers may find that implementing these costs of worker injuries and illnesses, and recommended practices brings other benefits promotes a positive work environment. as well. The renewed or enhanced commitment The concept of continuous improvement is to safety and health and the cooperative central to the recommended practices. As with atmosphere between employers and workers any journey, the first step is often the most have been linked to: challenging. The idea is to begin with a basic • Improvements in product, process, and program and grow from there. By initially service quality. focusing on achieving modest goals, monitoring • Better workplace morale. performance, and evaluating outcomes, you can help your workplace progress, over time, along • Improved employee recruiting and retention. the path to higher levels of safety and health. • A more favorable image and reputation (among customers, suppliers, and the community).

A study of small employers in Ohio found that workers’ compensation claims fell dramatically after working with OSHA’s SHARP program to adopt programs similar to those described in these recommended practices.

+

average claims number of claims co st p er c la im (per million average lost time per claim DECREASED DECREASED dollars of payroll)

D EC REASED 52% DECREASED 80% 87% 88% Source: Ohio Bureau of Workers’ Compensation (2011), Ohio 21(d) SHARP Program Performance Assessment.

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INTRODUCTION

IMPLEMENTING a safety & health program

can help employers avoid the INDIRECT COSTS that result from WORKPLACE INCIDENTS such as

TIME due to work training and other LOSS OR LOST stoppages and costs associated with and DAMAGE to material, investigations, REPLACING machinery INJURED and property. WORKERS

These INDIRECT have been estimated 2.7 COSTS to be at least times the DIRECT COSTS Source: Leigh, J.P. (2011), Economic Burden of Occupational Injury and Illness in the United States. Milbank Quarterly, 89:728-772.4

HOW TO USE THE RECOMMENDED have implemented (or will implement) each PRACTICES action item.

Each section of the recommended practices Seven interrelated elements describes a core program element (see page 7), followed by several action items. Each The seven core elements are interrelated and action item is an example of steps that employers are best viewed as part of an integrated system. and workers can take to establish, implement, Actions taken under one core element can (and maintain, and improve your safety and health likely will) affect actions needed under one or program. You can use the self-evaluation tool more other elements. For example, workers must found on the recommended practices Web page be trained in reporting procedures and hazard to track your progress and assess how fully you identification techniques in order to be effective

4 The 2.7 multiplier for indirect costs includes some social costs, such as workers’ compensation costs not covered by insurance.

4 RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS osha.gov/safetymanagement

INTRODUCTION

10 EASY THINGS TO GET YOUR PROGRAM STARTED If these recommended practices appear challenging, here are some simple steps you can take to get started. Completing these steps will give you a solid base from which to take on some of the more structured actions presented in the recommended practices.

1. SET SAFETY AND HEALTH AS A 6. COLLECT HAZARD CONTROL TOP PRIORITY IDEAS Always set safety and health as the top priority. Tell Ask workers for ideas on improvements and follow up your workers that making sure they finish the day and on their suggestions. Provide them time during work go home safely is the way you do business. Assure hours, if necessary, to research solutions. them that you will work with them to find and fix any hazards that could injure them or make them sick. 7. IMPLEMENT HAZARD CONTROLS Assign workers the task of choosing, implementing, 2. LEAD BY EXAMPLE and evaluating the solutions they come up with. Practice safe behaviors yourself and make safety part of your daily conversations with workers. 8. ADDRESS EMERGENCIES Identify foreseeable emergency scenarios and develop 3. IMPLEMENT A REPORTING instructions on what to do in each case. Meet to SYSTEM discuss these procedures and post them in a visible Develop and communicate a simple procedure for location in the workplace. workers to report any injuries, illnesses, incidents (including near misses/close calls), hazards, or safety 9. SEEK INPUT ON WORKPLACE and health concerns without fear of retaliation. CHANGES Include an option for reporting hazards or concerns Before making significant changes to the workplace, anonymously. work organization, equipment, or materials, consult with workers to identify potential safety or health 4. PROVIDE TRAINING issues. Train workers on how to identify and control hazards using, for example, OSHA’s Hazard Identification 10. MAKE IMPROVEMENTS Training Tool. Set aside a regular time to discuss safety and health issues, with the goal of identifying ways to improve 5. CONDUCT INSPECTIONS the program. Inspect the workplace with workers and ask them to identify any activity, piece of equipment, or material that concerns them. Use checklists, such as those included in OSHA’s Small Business Handbook, to help identify problems.

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participants. Thus, the “Education and Training” to integrate their safety and health program with core element supports the “Worker Participation” other programs that they are using to manage core element. Similarly, setting goals (as production, quality control, and environmental described under “Management Leadership”) will protection or sustainability. be more effective if you routinely evaluate your progress in meeting those goals (see “Program The importance of worker Evaluation and Improvement”). Progress in each participation core element is important to achieve maximum Throughout these recommended practices, benefit from the program. OSHA emphasizes the importance of worker participation in the safety and health program. One size does not fit all For a program to succeed, workers (and, While the action items under each core element if applicable, their representatives) must are specific, they are not prescriptive. The participate in developing and implementing process described in these recommended every element of the safety and health program. practices can, and should, be tailored to the This emphasis on worker participation is needs of each workplace. Likewise, your safety consistent with the OSH Act, OSHA standards, and health program can and should evolve. and OSHA enforcement policies and procedures, Experimentation, evaluation, and program which recognize the rights and roles of workers modification are all part of the process. You and their representatives in matters of workplace may also experience setbacks from time to safety and health. Several action items described time. What is important is that you learn from in these recommended practices rely on setbacks, remain committed to finding out what perspectives, expertise, and input that can come works best for you, and continue to try different only from workers and their representatives. approaches.

Injuries and illnesses occur in all types of When more than one employer is workplace settings, from manufacturing sites, to involved hospitals and healthcare facilities, to offices and Host employers, contractors, staffing agencies, service industries.5 Workers can even be injured and their workers should pay particular attention or become ill outside physical facilities, such to the “Communication and Coordination for as when driving a vehicle as part of a sales or Host Employers, Contractors, and Staffing service job. The preventive approaches described Agencies” section. This section describes in these recommended practices work equally actions that host employers and contractors, well across all sectors of the economy; for all subcontractors, and temporary staffing agencies different kinds of hazards; in both mobile and (and their workers) should take to ensure fixed work environments; and for small, medium- protection of everyone on the worksite. sized, and large organizations. Small employers may find that they can best accomplish the actions outlined in these recommended practices using informal communications and procedures. For tools and resources to help you Larger employers, who have more complex work implement these recommended practices, processes and hazards, may require a more visit: osha.gov/safetymanagement formal and detailed program. They may also wish

5 Please note: OSHA has developed a separate document of Recommended Practices for Safety and Health Programs for the Construction Industry.

6 RECOMMENDED PRACTICES FOR SAFETY AND HEALTH PROGRAMS osha.gov/safetymanagement

INTRODUCTION

CORE ELEMENTS OF THE SAFETY AND HEALTH PROGRAM RECOMMENDED PRACTICES • Top management demonstrates its commitment to continuous improvement in safety and health, communicates that commitment to workers, and sets program expectations and MANAGEMENT responsibilities. LEADERSHIP • Managers at all levels make safety and health a core organizational value, establish safety and health goals and objectives, provide adequate resources and support for the program, and set a good example.

• Workers and their representatives are involved in all aspects of the program—including setting goals, identifying and reporting hazards, investigating incidents, and tracking progress. • All workers, including contractors and temporary workers, understand their roles and WORKER responsibilities under the program and what they need to do to effectively carry them out. PARTICIPATION • Workers are encouraged and have means to communicate openly with management and to report safety and health concerns without fear of retaliation. • Any potential barriers or obstacles to worker participation in the program (for example, language, lack of information, or disincentives) are removed or addressed.

• Procedures are put in place to continually identify workplace hazards and evaluate risks. • Safety and health hazards from routine, nonroutine, and emergency situations are identified HAZARD and assessed. IDENTIFICATION & • An initial assessment of existing hazards, exposures, and control measures is followed by periodic inspections and reassessments, to identify new hazards. ASSESSMENT • Any incidents are investigated with the goal of identifying the root causes. • Identified hazards are prioritized for control.

• Employers and workers cooperate to identify and select methods for eliminating, preventing, or controlling workplace hazards. HAZARD • Controls are selected according to a hierarchy that uses engineering solutions first, followed by PREVENTION & safe work practices, administrative controls, and finally personal protective equipment (PPE). CONTROL • A plan is developed to ensure that controls are implemented, interim protection is provided, progress is tracked, and the effectiveness of controls is verified.

• All workers are trained to understand how the program works and how to carry out the responsibilities assigned to them under the program. EDUCATION & •E mployers, managers, and supervisors receive training on safety concepts and their responsibility for protecting workers’ rights and responding to workers’ reports and concerns. TRAINING • All workers are trained to recognize workplace hazards and to understand the control measures that have been implemented.

• Control measures are periodically evaluated for effectiveness. PROGRAM • Processes are established to monitor program performance, verify program implementation, EVALUATION & and identify program shortcomings and opportunities for improvement. IMPROVEMENT • Necessary actions are taken to improve the program and overall safety and health performance.

• Host employers, contractors, and staffing agencies commit to providing the same level of COMMUNICATION AND safety and health protection to all employees. COORDINATION FOR • Host employers, contractors, and staffing agencies commmunicate the hazards present at the worksite and the hazards that work of contract workers may create on site. HOST EMPLOYERS, • Host employers establish specifications and qualifications for contractors and staffing agencies. CONTRACTORS, AND • Before beginning work, host employers, contractors, and staffing agencies coordinate on work STAFFING AGENCIES planning and scheduling to identify and resolve any conflicts that could affect safety or health.

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INTRODUCTION

FOR MORE INFORMATION On-site Consultation Program services are separate from enforcement and do not result in penalties For more information about these recommended or citations. Consultants from state agencies practices, tools to help you implement them, and or universities work with employers to identify related topics, see the recommended practices workplace hazards, provide advice on compliance Web page. This page includes links to many tools with OSHA standards, and help them establish and and resources developed by OSHA and others improve their safety and health programs. that can help employers and workers implement these recommended practices. OSHA will continue