The Importance of Site Specific Safety and Health Management Plans
A good safety and health management (S&HM) plan should be comprehensive and site specific, and yet it is often one of the most overlooked and underappreciated tools in the safety department. Many company safety representatives believe that if you have some sort of a written plan, you have it made. That viewpoint is not always correct.
A site specific plan should be based on the company's types of hazards, its industry and its involved tasks, including but not limited to: emergency action, lock out/tag out, respirator, hearing conservation, HazCom, process safety management, personal protective equipment, blood borne pathogens, chemical hygiene, permit required confined space, and fall protection plans. Frequently, these plans are OSHA mandated in specific standards for the general, maritime and construction industries. Each standard delineates the contents and requirements for their specific plans.
Developing a safety plan from scratch is time consuming and often costly. And like anything else, a plan is only as good as the time and effort spent developing it. By the same token, a 400-page plan is not necessarily better than a well-drafted 40-page plan.
Several years ago, USF SafetyFlorida realized this and developed a useful Web-based software program called SafetyWriter. Located on our website, www.usfsafetyflorida.com, SafetyWriter, provides companies with a comprehensive and easy to use safety plan template in both English and Spanish. To date, the program has been used thousands of times nationwide, providing companies with an effective means of developing their safety plan foundation.
Although this template contains the necessary information to meet OSHA standards, companies must still complete their plan by adding their own site specific and pertinent information. Only then, will the plan become comprehensive and truly site specific.
In addition to the specific OSHA standards requirements, the following elements should be considered when developing a site-specific safety plan:
Management Safety Policy Statement. This statement expresses the company’s safety commitment and involvement. Furthermore, it should be signed by the company's top executive and display their intention to comply with all applicable local, state, and federal safety requirements and appropriate industry standards.
Safety Rules. These specific safety rules apply to the operations being performed and should be short, concise, simple, enforceable and stated in a positive manner. They are to be followed and adhered to by all management personnel and employees, and a copy should be provided to each employee and documented.
Safety Responsibility. This responsibility should be defined in writing for executive and middle level operating management, supervisors, safety coordinator and employees.
Worksite Analysis. An analysis should be routinely conducted of all areas of the work place by a lead worker or supervisor or a safety coordinator at the site. After each inspection, a written report should be completed and retained for record. The report is designed to address any unsafe conditions identified as well as unsafe acts and any other items inherent to a particular job. Furthermore, the report should include what corrective actions are to be taken and management's designated responsibility for the correction of defects.
Hazard Prevention and Control. All hazard control strategies must be illustrated to include A) engineering controls and administrative applications and limitations, B) management controls and strategies, C) personal protective equipment and D) interim or temporary measures.
Safety Training. Management should implement a training program that provides orientation and training for each new employee, existing employees on a new job, or when new equipment, processes or job procedures are initiated. The training should consist of, but not be limited to, correct work procedures to follow, correct use of required personal protective equipment, and where to get assistance when needed. This training should also be accomplished by the employee's supervisor but may be done by a training specialist or an outside consultant such as a vendor or safety consultant. Training shall be provided to all persons in operating supervisory positions in conducting safety meetings, conducting safety inspections, accident investigation, job planning, employee training methods, job analysis and leadership skills.
Records will be kept showing the safety topics discussed, date(s) of meeting and the names of the persons attending.
Safety meeting topics will be designed to instruct employees on how to perform their jobs productively, efficiently and safely. Hazard recognition and hazard control procedures; selection, use, and care of personal protective equipment; job procedures review; and good housekeeping are examples of the information employees should receive at a safety meeting.
A review of the recent work area inspection results, the workers' compliance with safety procedures, and the accident investigations that occurred since the last safety meeting should be covered in the safety meeting.
First Aid. Management shall adopt and implement a first aid program, which will provide for a trained first aid person at each job site on each shift. A first aid kit with proper supplies for the job exposures will be maintained and restocked as needed. Emergency phone numbers for medical services and key company personnel must also be maintained.
Accident/Incident Investigation Procedures. The accident/incident investigation report includes information required to determine the basic causes of the accident or incident by asking the questions who, what, where, when and how. Corrective action to be taken and/or recommended to prevent a recurrence of a similar accident will be implemented. Complex accidents may require technical assistance to ensure an accurate investigation; however, the injured employee's supervisor should be included on the investigation team.
The accident/incident investigation report shall include information on the injured person, his or her job, what happened, basic causes, corrective actions required, the time frame to make corrections, and who will be responsible for seeing that corrections are implemented.
Record Keeping. In addition to OSHA logs, which are retained for five years (a federal requirement), each firm shall maintain other safety records for a period of one year from the end of the year for which the records are maintained (a state requirement). These will include inspection reports, accident investigation reports, minutes of safety meetings and training records.
Emergency Action Plan. Management shall develop a written emergency action plan to ensure to the extent possible the safety of all employees, visitors, contractors and vendors in the facility at the time of emergency situations, such as but not limited to natural disasters, fire, explosions, chemical spills and/or releases, bomb threats, and medical emergencies. Emergency shutdown and startup procedures will be developed in industries having equipment that requires several steps to properly shutdown and secure. Employees shall be trained in these procedures to reduce the incidences of additional injuries, property damage, and possible release of hazardous materials to the environment. Emergency plans shall comply with all governmental regulations and state and local emergency response committee requirements.
All employees and contractors shall be trained in the facility's emergency plan. A facility training drill will be conducted at least annually to test the emergency plan. The emergency plan will be reviewed annually and revised as required. Employees shall be trained in the updated emergency plan. Monthly inspections of all access and egress aisles and doors will be conducted to determine that they are clear, unobstructed, and operable. Evacuation routes shall be posted in all work areas showing primary and secondary routes for employees' evacuation to a safe, predetermined location for a head count.
It is important to note that when developing your own safety plan, use titles instead of identifying specific employees unless the turnover rate is minimal. All site specific plans should include a date of revision and site address as well.
Once all information is in place and the plan is printed, it then must be implemented. Too often, consultants come across safety plans that are well written but poorly executed. Implementation must take place through an all-inclusive training program and enforcement of company policies and OSHA standards.
In summary, management should review its safety plan on a regular basis. Templates are a great start, but plans must include site specific information in order to comply with OSHA standards. If you have a plan or are in the process of developing a plan, take care to ensure the above elements are included. Furthermore, management must disseminate the information and enforce its policies.