Building a solid OSHA program requires putting programs into practice

1.    Develop the various programs required by the OSHA standards;

2.    Integrate those programs into the daily operations;

3.    Investigate all injuries and illnesses;

4.    Provide training to develop safety competence in all employees; and

5.    Audit your programs and your work areas on a regular basis to stimulate continuous improvement. 

With those steps in mind, let's start with OSHA compliance. Aside from being a requirement for general industry, the OSHA standards provide a good pathway to incident reductions. 

A good number of accidents stem from poorly developed, poorly trained, or poorly implemented OSHA programs. Slips or trips may come from poor housekeeping efforts or not keeping walking and working surfaces clear. Not using personal protective equipment may result in excessive lacerations. Poor lifting techniques can result in strains.

Many of the OSHA standards require some type of written program be developed and then communicated to employees. Experience shows that companies with thoroughly developed OSHA-compliant programs have fewer accidents, more productive employees and lower workers' compensation costs.

But policies alone won't get results; the program must move from paper to practice to succeed. Putting a policy into practice requires a strategic plan clearly communicated to key participants, good execution of that plan based on developed competencies, and a culture that inspires and rewards people to do their best. 

When developing any business initiative there must be an emphasis on frontline supervisors and helping them succeed. Every good business person knows that any new program, be it safety, quality or anything else, lives and dies with the frontline supervisor.  If the frontline supervisor knows the program and wants to make it happen, the program succeeds; if not, the program is a source of constant struggle and an endless drain on resources and energies. Providing supervisors with knowledge and skills through training is critical to the success of any program. 

A solid OSHA program, integrated into the daily operation and led by competent supervisors is just the beginning. Successful safety programs focus on being proactive instead of always reacting to issues.  Accident investigations provide an excellent source of information on real or potential issues present in the workplace.

The role of accident investigation

Worker's compensation is designed to recompense employees for injuries or illnesses that result in or out of the course of employment. This should not come as a surprise, but increasing claims drive up workers' compensation costs. To reduce those costs, you must reduce your accidents; it's just that simple.  And the ability to reduce accidents is significantly enhanced when those accidents are fully investigated instead of simply being reported. 

Accident reports are historical records only citing facts while accident investigations go deeper to find the root cause and make improvements.  Businesses that stop rising work comp costs have an effective accident investigation process that ferrets out the root cause of the problem.  Unless the root cause is discovered, recommendations for improvement will remain fruitless.  Again training proves beneficial because a supervisor skilled in incident analysis is a better problem solver for all types of production-related issues; not just safety.

Which accidents should be investigated?  All accidents should be investigated to find out what went wrong and why.  Some may suggest investigating every accident is a bit over the edge and only those that incur significant costs are worthy of scrutiny.  But ask yourself this question: If you only investigated serious quality concerns instead of every little deviation, would your quality program still be as effective as it is?  Companies with solid quality programs investigate and resolve every deviation from quality standards.  Here's the key: accidents are deviations from your safety program and warrant your full attention to find the root cause.

You will reduce your workers' compensation costs if you investigate all accidents. If your emphasis is only on those incidents that have to 'recorded' on the OSHA 300 Log, you close your eyes to the biggest accident category of 'first aid only' incidents. Many companies get upset about 'recordables' or 'lost time incidents' because of the significant costs involved but then they don't go far enough with problem resolutions. But recordable and lost time incidents don't make up the largest block of incidents; it is first aid only incidents that are the largest category. 

Statistically it is proven that for every 100 accidents, 10 will be recordable and one a lost time incident.  If you investigate only recordables or lost time accidents, 89 of your incidents go unnoticed.  Again, using the Quality program analogy, would you consider a quality program that allows an 89% failure rate successful? Hardly! It doesn't take a PhD in mathematics to see that reducing serious accidents means you must reduce your overall base of all accidents - including first aid incidents.  That only happens when every incident is fully investigated to find the root cause and remedial actions are identified and integrated into the daily operation. 

Training and auditing for continuous improvement

The final steps focus on training and auditing your program for continuous improvement.  Training plays a significant role in safety and in reducing work comp costs.  The goal of training is to develop competent people.  What is competency?  Competency is when people have the knowledge, skill, and understanding to perform assigned job responsibilities. Competence, more than anything else, will improve all aspects of your business and drive down costs. Supervisors must have the knowledge and ability to integrate every safety program into their specific areas of responsibility.  Every employee must know what is expected of them when it comes to implementing safe work procedures. Once the programs are developed and implemented, they must be reviewed on a regular basis to make sure they are still relevant and effective. 

Might all of this require a change in how you manage your safety program?  Well, if your workers' compensation rates are high because you have a poor safety program, you better change how you manage your safety program.  Back in the 1980s when 'quality' went through its renaissance, was it necessary for companies to make some changes in how their quality programs were managed?  The same thing is necessary with 'safety' and having an effective safety program. 

Tangible benefits

u  There is a return on investment and direct bottom-line benefits can be seen when a safety program is properly designed, implemented and integrated into the daily operation.

u  A competency-based safety program is compliant with OSHA requirements and therefore reduces the threat of OSHA fines.

u  A competency-based safety program lowers accidents and fewer accidents lowers workers' compensation costs. When incidents do occur, a competency-based safety program fully evaluates the issue and finds the root cause to prevent reoccurrence and provides a workplace that is free from recognized hazards that injure people.

u  A safer workplace creates better morale and improves employee retention. Auditing keeps your programs fresh and effective and drives continuous improvement.

u  Finally, a competency-based program produces people who are fully engaged in every aspect of their job and are satisfied and fulfilled producing high-quality goods and services.