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Setting the Stage for Safety |
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New Year Offers Opportunity for Policy Changes -
by Robert Baldwin |
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The beginning of each
year presents a unique opportunity to start over
with a fresh resolve for a new beginning. Now is
the time to set a tone, a direction, a new
policy that will not be seen as a midstream
course correction or inexplicable random change. |
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It is a perfect time to reflect on problems of
the past year and focus energy on improvements.
Regulatory paperwork offers an easy tool for
doing just that. At the end of December 2005
your business recorded (or should have recorded)
the last of any accidents or injuries on the
OSHA 300 Log. This official U.S. Department of
Labor form is an official record of the safety
performance of your firm.
Official filing rules
now require that a corporate officer sign the
document in order to close the year-end
performance. Now is an excellent time to review
the rules for recordability before executing
this official document. The requirement for an
employee posting of the document will become
necessary in February.
Logging the
results
Once reviewed and executed, the OSHA 300 Log
becomes a powerful measuring stick for setting
performance expectations for the upcoming year.
A 300 Log with no injuries is an occasion for
congratulations and encouragement to continue
the good work, while a 300 Log filled with
recordable
accidents and injuries presents an occasion to
set aggressive goals to improve safety.
All companies large and small can use this
technique to set goals.
Once identified, the next step is to ensure that
a policy and program are in place to provide
employees with work rules and procedures. If
injuries exist, for example, are there formal
methods of preventing them?
For instance, sprains and strains may indicate a
need for mechanical lifting equipment or a new
procedure that eliminates the hazard exposure,
such as a requirement for “two-person” lifting
of heavy items.
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Assistance
available
Sound a little overwhelming for the staff
resources available? Not to worry as Indiana’s
OSHA program (known as IOSHA) has an assistance
program for employers. One of the first
priorities of Indiana Commissioner of Labor
Miguel Rivera was to revitalize the former BuSET
(Bureau of Safety Education and Training).
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Since his
appointment, Rivera has dusted off the data the
state has collected over the past several years
and analyzed the accident and injury trends. He
has on several occasions stated that IOSHA knows
where the problems are and the areas in which
the injuries are occurring. He has stated that
participation to improve accident and injury
rates is much preferred to the issuance of
citations.
Targeting punitive enforcement actions at
companies in which accidents are most likely to
occur is a method widely used in federal OSHA
jurisdictions. Critics of state managed plans
point to comparisons of accident and injury
rates in federal vs. state programs. One look at
the graph clearly shows that while accident and
injury rates are showing progressive
improvement, Indiana (a state-managed OSHA
program) is not doing as well as Illinois (a
federal-managed OSHA program). Comparisons such
as this weaken the argument for state control of
compliance programs and give rise to
speculations of planned citation actions.
One example of increased punitive actions to
encourage workplace safety is occurring in the
state of Florida. Faced with a large and growing
number of workplace injuries and fatalities, the
Southeast region has begun “saturation
enforcement inspections.” This is a process in
which additional OSHA compliance inspectors from
as far away as Alabama are brought into Florida
to conduct dozens of random inspections in an
effort to place direct punitive pressure on all
employers in the area. There is even evidence to
suggest that Florida OSHA has shared citation
information with local media, causing a broad
communication of one company’s safety status and
resulting in some embarrassment.
There is no concern that such measures will ever
be utilized in Indiana’s state plan, although
the focus and frequency of punitive fines from
the IOSHA compliance officers ultimately will be
determined by our own efforts to create and
enforce a “safe” place in which to work. |
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Author: Robert
Baldwin is CEO of Safety Resources, Inc. in
Zionsville, Indiana. The team of consultants
works in the structure and implementation of
workplace safety, corporate loss control and
regulatory compliance programs. Baldwin can be
contacted at (317) 871-8155.
BizVoice/Indiana Chamber – January/February 2006
Reprinted with permission. |
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