There are many steps to developing a safety program, the first of which is determining the scope of the program to be developed. We have developed safety programs for single OSHA standards such as lockout/tagout (LOTO), electrical safety, machine guarding, etc. We have also developed entire safety programswhich cover all of the applicable standards for a given client. For general industry this could mean up to 35-40 individual OSHA standards as well as related standards issued by the American National Standards Institute (ANSI) and the National Fire Protection Agency (NFPA), among others.
The Safety Professional (SP) developing these programs needs to be very well versed in the OSHA, NFPA, ANSI and other applicable standards for a given client. Knowledge of and understanding these standards are a good start but will not be enough to develop a complete safety program. Interpreting and implementing the standards will also be required to succeed in delivering a complete program. The SP will need to have additional skills such as assessing, hazard recognition, negotiating, communication, documentation, training development and delivery for classroom and hands-on as well as coaching, directing and skills for handing off the program.
The purpose of the assessment is to gain an understanding of what the client’s workforce is exposed to related to their day-to-day operations. The site walk-through (there may be more than one), and employee interviews are critical to the assessor, as knowing everything that employees work on is key to determining the total scope of the project. During the walk-through and the interviews the assessor can determine exactly which standards are applicable and which are not. It is essential to ensure that the safety program only includes applicable standards. While assessing, the SP can ask questions about activities that either bring a standard into the scope of the program or which standards should be eliminated from the program. One interview question might be, “does the company perform its own maintenance?” This question alone when answered in the affirmative can bring in several standards like lockout/tagout, machine guarding, ladder safety, personal protective equipment (PPE), etc. If this question is answered in the negative, some of these standards may drop out. When the assessment is completed, documented and shared with the client contacts, the SP should have a very good idea of the scope of the program and can proceed to the next step.
Documenting the Program
Each applicable standard will then need to be developed into a plan or policy specific to the clients operations. If Lockout/Tagout (LOTO) is applicable to the client, the Occupational Safety and Health Administration (OSHA) 29CFR1910.147 will need to be addressed. Further investigation by the assessor will determine exactly what LOTO procedures or practices will need to be developed for which equipment. If the client performs their own electrical work, they will need to be in compliance with NFPA 70 and NFPA 70E if they work energized and so on. These documented plans and policies may be as short as a single page or up to 20+ pages in length depending on the client’s circumstances and must be read, understood and approved by the client.
Implementing the Program
Program implementation is the next phase and can be the most difficult to complete. Implementation is basically the handoff of the program to the client so that they have a lasting process and not just a book of plans or a safety manual sitting on a shelf. This handoff can be very simple for single standard programs or quite extensive from a time to implement perspective where multiple standards are involved. The most important factor in the work required to implement a safety program is the people the client will be using to receive the handoff. The knowledge, talents and skills sets the client’s employees bring to the table are the real keys to how the implementation will progress. If the client has well trained safety personnel that know and understand the applicable standards, the implementation goes faster than if the client has no personnel trained to this extent. For the client with few if any trained employees, program implementation will include extensive time for train-the-trainer on all applicable standards contained in the safety program. Some clients have never included safety in their management system and when this is the case, we are looking at making a major culture change.
At Optimation we have the personnel and the skill sets to develop safety programs for almost every type of general industry client and have done so on several occasions. The scope work has included developing safety manuals, policies, procedures, forms and checklists, developing and delivering safety training, train-the-trainer programs in both the classroom and in the field and much, much more. Corporations large and small need to have a safety program specific to the scope of their work. Those corporations without a safety program should seriously consider putting one in place. Corporations with a safety program should review them frequently and keep them up-to-date. It is far better to have a pro-active safety program than having to react to the unplanned consequences.