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Excerpts and Comments on OSHA's Voluntary Guidelines for Workplace Safety and Health Program Management

In OSHA's 1989 publication, Voluntary Guidelines for Safety and Health Program Management, "Employers are advised and encouraged to institute and maintain in their establishments a program which provides systematic policies, procedures, and practices that are adequate to recognize and protect their employees from occupational safety and health hazards." More than 21 years after its publishing, The Guidelines' recommendations are as important today, if not more so, than they were then.

Keith Brown

Keith Brown

Safety Team Leader and Supervisor

In particular, three points should be considered by every employer and employee involved in their workplace's safety and health management system, as well as by those not currently involved and who need to get involved.

  1. Protecting employees from occupational safety and health hazards may be better understood to say that the end, many times, determines the means. The criterion for what is needed in a safety and health program at a particular site is whatever feasible action it takes to protect the workers from the safety and health hazards at that site. The form of the safety and health program elements and implementing actions will vary according to the nature of site organization and the nature of the hazards and potential hazards at the site.
  2. The Guidelines state, "An effective program includes provisions for the systematic identification, evaluation, and prevention or control of general workplace hazards, specific job hazards and potential hazards, which may arise from foreseeable conditions." Provisions for identifying and preventing hazards are systematic. If not, hazards or potential hazards will be missed and/or preventive controls will break down, and the chance of injury or illness will significantly increase.
    General workplace hazards are conditions such as tripping hazards in walking areas and poor illumination. Specific job hazards relate to the conditions in a particular job, such as exposure to a saw blade, or to the inherent hazardousness of an operation required in the job, such as the removal of jammed material from a point of operation. Potential hazards include the possibility of exposure to toxic chemicals as a result of a rupture of piping from the impact of a forklift.
  3. The Guidelines also point out that, "Although compliance with the law, including specific OSHA standards, is an important objective, an effective program looks beyond specific requirements of law to address all hazards. It will seek to prevent injuries and illnesses, whether or not compliance is at issue."
    OSHA and other government standards provide important guidance on identifying and controlling hazards, but they are not always enough. Although compliance with the law is an important objective of and motive for an effective program, the most successful programs look beyond government standards and legal requirements. They look for other sources of information about hazards, such as the National Electrical Code (NEC), the American Conference of Government Industrial Hygienists (ACGIH), and the American National Standards Institute (ANSI), and they use their own experience and abilities to look for and address hazards not covered by government or other standards. The motive should be to prevent injuries and illnesses and the associated human and economic costs, whether or not compliance with the law is at issue.