Is your safety program robust without being excessive?

You ask, “Can a safety program be excessive?” In short, yes.

Companies of all sizes that perform the majority of their work on other companies’ sites are the most common victims of this practice: logorrheic Health, Safety and Environmental Manuals. I say victims because these organizations are doing what they think is being asked of them – either through misguidance or misinterpretation.

While TMI finds its roots in the shorthand jargon of the tech/social media age, it simply means too much information.

A vast majority of organizations invest inordinate amounts of resources developing Occupational Health and Safety Management Systems (OHSMS) that end up being labyrinthine and loquacious. Garrulous and circumlocutory safety programs inhibit employees’ ability and desire to understand and comply.

A diffuse safety program is not concentrated or localized.

Using all of those words and ideas to simply say “overkill” makes the point.

More may look better to the untrained eye, but it can come off as trying to impress, as well as clearly indicate that someone went (online?) and grabbed everything they could – whether it is needed or not.

A careful analysis of an organization’s actual processes and workers’ functions will dramatically increase the value of the OHSMS by appropriate streamlining. If some policy or procedure is in your safety program, you are expected to comply with what you have written. If it is not truly relevant or does not apply, leave it out.

How do you develop a precisely robust OHSMS?

OSHA (TOSHA) gives the following guidance for Written Programs.

The written program is the employer’s statement as to how he/she will protect employees from a specific hazard. Once the program is written, you must follow the program. Use care in writing it and ensure that it is actually what you will do in the workplace.

 

Well Written Programs 

  • are site-specific

  • cover only what is needed for each site–short and sweet

  • are practical and tested

  • are updated as needed

Poorly Written Programs

  • are not written for the site

  • just restate the standard

  • are written without knowledge of the standard

  • have missing information or blanks

The point being, simpler is better. Answering the following questions will point you in the right direction.

  1. What components of an Occupational Health and Safety Program (OHSP) or OHSMS does OSHA expect for my organization?

  2. Would ISO 45001 be a more meaningful OHSMS for my organization?

  3. What processes and equipment does my organization actually own and control?

  4. What work do my employees perform at my facility?

  5. What work do my employees perform at client-controlled sites/facilities?

  6. What safety programs are required by clients? These can be provided through Site Safety Plans.

  7. Does it make more sense to have a precisely robust OHSP or OHSMS for my organization and utilize Site Safety Plans for the client-controlled sites/facilities?

While navigating the more is better approach to business in 2020, for Occupational Health and Safety Management Systems, precisely robust means less is better. Too much information is just that. Too much information.