What starts at the top, though, must filter down through the ranks.
“From a legal perspective, a business operates through its managers and supervisors,” Nichols says. “What they do or don’t do is often imputed to the employer. New hires must be properly trained from a safety perspective before they begin work.”
As the first line of defense against penalties, supervisors must ensure rules and regulations are applied throughout the workplace. Existing employees must also receive appropriate periodic and updated training. That can occur through monthly or weekly safety orientations, which are sometimes referred to as “toolbox” or “tailgate” meetings. Some companies schedule these at the beginning of every shift.
Getting specific
OSHA will look for policies and practices that are site specific, says Gary Heppner, an independent OSHA safety advisor.
“An inspector typically goes into a shop, removes guards from a drill press and then picks somebody at random to set up the press and drill an obscure hole in the metal,” Heppner says. “The employee’s actions must reflect training specific to that machine.”
It’s not good enough to just download some safety boilerplate from the internet, Heppner adds.
“If OSHA sees a company’s policies are too general, they may do a fishing expedition to find out what is lacking in the program,” he says.
Once specific policies are in place, it’s important to perform ongoing monitoring.
“As the eyes and ears of the company, supervisors should walk the floor during the workday, not only checking the production line but also making sure people are not violating safety rules,” Foulke says. “Are they wearing their personal protective gear? Working the equipment properly? The supervisor should fill out a form that records what inspections were done and what remedial actions were taken when violations were identified.”
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Regular workplace tours provide excellent opportunities to obtain feedback from those on the front lines.
“Where supervisors often fall short is in not having employees be active safety participants,” Witte says. “Instead of just telling them how to operate a machine, establish two-way communication. Do they have additional safety concerns beyond what has been discussed? Sometimes a machine may not be working exactly as designed, and that can have safety ramifications.”