Developing Effective Safety Management Programs

Overview

Lax attitudes about workplace safety pose greater dangers in some industries than in others, but no organization can afford to ignore efforts to instill safety consciousness throughout its workforce. This article discusses the development and implementation of effective safety management programs, the legal issues associated with safety programs and the design and implementation of effective safety management programs. For an overview of employer requirements to provide a safe and healthy workplace, see Employer Responsibilities.

Business Case for Safety Management Programs

According to the National Safety Council, the total cost of work injuries in 2019 was $171 billion, including wage and productivity losses, medical expenses, administrative expenses and other uninsured costs.

In addition, violation of workplace safety standards come with stiff penalties. The Occupational Safety and Health Administration (OSHA) adjusts penalties for employer violations based on inflation no later than Jan. 15 of each year. The financial impact of safety violations can be devastating for some employers. Annual adjusted penalties can be found on the OSHA website.

A culture of safety awareness aimed at minimizing workplace injuries can both rein in workers' compensation costs and medical expenses associated with injuries and help employers avoid liability for negligence, increase employee morale and productivity, and cut absenteeism.

Designing a safety program

The critical elements of an effective safety management program are:

• Management commitment.
• Communication.
• Employee involvement.
• Worksite analysis.
• Hazard prevention and control.
• Training for employees, supervisors and managers.

See:

OSHA: Recommended Practices for Safety and Health Programs

OSHA: Tools for Safety and Health Programs

How to Determine Regulatory Requirements for Safety

What You Need to Know About ... OSHA

Management commitment

A safety management program cannot be successful without the active support of senior management; support includes allocating resources to safety programs and demonstrating the organization's commitment to safety. Top management should be involved in implementing and communicating the program so that all employees understand that management's commitment is serious. Members of management may also demonstrate their commitment by:

• Requiring accountability from all employees for safety and health matters.
• Integrating safety and health into business practices (e.g., purchases, contracts, design and development).
• Involving employees in safety and health-related activities (e.g., self-inspections, accident investigations and the development of safe work practices).
• Ensuring that written program goals, objectives, policies, procedures, implementation plans and review processes are communicated to employees. The CEO should sign those written statements to demonstrate management's commitment to the program.

See Viewpoint: How to Foster a Culture of Workplace Safety

Communication

The overall effectiveness of workplace safety and security measures depends on an organization's ability to effectively communicate safety and security goals and objectives. A communication strategy should be devised and implemented in a manner that supports the goals and objectives of the safety management program. The steps in developing a safety communication strategy are:

• First, identify the most important communications involving workplace safety and security issues, and establish a baseline for later comparison.
• Next, establish goals and objectives to enable implementation and monitoring of carefully targeted measures.
• Finally, follow up and obtain outcome data to determine if the communication plan has worked and if it continues to have a positive impact.

See Managing Organizational Communication.

An effective safety and security communication strategy also identifies the intended audience, the tools to be used, a timeline and a budget. Tools may include the following:

• Memos.
• E-mails.
• Intranet messages.
• Webinars.
• In-person staff meetings.
• Virtual group meetings.
• Review of new safety and security policies in department meetings.

See The Best Ways to Roll Out New Workplace Safety Programs

Basic questions that organizations should address in a safety and security communication plan for a targeted audience include:

• How do these policies and procedures affect my safety and security in the workplace?
• What are my employer's expectations for my involvement in safety and security programs?
• What are my job requirements as they relate to safety and security?
• What regulations apply to my job?

Employee involvement

Experience has shown that a further basic requirement of any good safety and health program regardless of size or type of workplace is to ensure employee participation in the design and operation of the program. The plan may involve a number of different structures for achieving employee participation: for instance, a safety committee, designation of key employees for various functions, ad hoc working groups or assignments within teams.

There are numerous reasons for seeking employee involvement in the design of safety management programs. Clearly, rank-and-file workers are the persons most in contact with potential safety and health hazards and thus have a vested interest in effective protection programs. In addition, group decisions have the advantage of the group's wider range of experience. Finally, employees are more likely to support and use programs in which they have input. Employee engagement surveys have shown that employees who are encouraged to offer their ideas and whose contributions are taken seriously are more satisfied and productive on the job.

Employee participation means that employees are encouraged to participate fully in the program, including in the review and investigation of injuries and illnesses, in periodic workplace inspections, in regular safety and health meetings, and in recommendations to the employer with respect to the administration of the program elements.

Examples of employee participation include the following:

• Participating on joint labor-management committees and other advisory or specific purpose committees.
• Conducting site inspections.
• Analyzing routine hazards in each step of a job or process and preparing safe work practices or controls to eliminate or reduce exposure.
• Developing and revising the site safety and health rules.
• Training both current and newly hired employees.
• Providing programs and presentations at safety and health meetings.
• Conducting or participating in accident and incident investigations.
• Reporting hazards.
• Fixing hazards within their control.
• Supporting co-workers by providing feedback on risks and assisting them in eliminating hazards.

• Performing a pre-use or change analysis for new equipment or processes to identify hazards up front before use.

Employers should clearly understand that employee participation arrangements may raise legal concerns. It makes good sense for employers to consult with their labor relations advisor to ensure that employee involvement programs conform to current legal requirements. See Could Your Employee Participation Program Be Illegal?

Worksite analysis

A worksite analysis is the identification of existing or potential hazards by conducting baseline worksite surveys for safety and health concerns. A worksite analysis often includes the following:

• Analysis of planned and new facilities, processes, materials, equipment, and routine job hazards.
• Regular site safety and health inspections to identify new or previously missed hazards and failures in hazard controls.
• A reliable system to encourage employees, without fear of reprisal, to notify management personnel about conditions that appear hazardous and to receive timely and appropriate responses.
• Investigation of accidents and near-miss incidents to identify their causes and means for prevention.
  
• Analysis of injury and illness trends over extended periods to identify patterns with common causes and to prevent future incidents.

See OSHA Hazard Identification and Assessment.

Hazard prevention and control

Hazard prevention and control procedures ensure that organizations correct all current and potential hazards in a timely manner through engineering techniques where appropriate; that safe work practices are understood and followed by all parties; that personal protective equipment is provided; and that administrative controls, such as reducing the duration of exposure, are in place and followed.

A key concept in making certain that safe work practices are followed is persuading employees of the need to actively notice new things. The rules should guide, rather than govern, their behavior. Being mindful of safety is different from vigilance, which involves a potentially exhausting level of concentration and a clear image of particular hazards, according to Ellen Langer, a Harvard University psychology professor.¹

An overly rigid approach to managing safe work practices may backfire if it burns out workers and fails to inspire them to pursue safety actively. For example, organizations that track the number of days without an accident and reward employees for reaching certain milestones might be encouraging deception rather than safety. Workers could feel pressured to avoid reporting an incident so they do not ruin the bonus for everyone.

As part of an overall hazard prevention and control plan, managers should focus on getting workers to report unsafe behaviors. Close calls allow people to learn without the terrible emotions that accompany tragedy.

Virginia Tech psychology professor and workplace safety expert E. Scott Geller advocates that employers observe employees on the job as a way to encourage them to adopt a culture of workplace safety. Here are some guidelines recommended by Geller:²

• Be communicative and supportive with employees. Make sure you avoid being confrontational or patronizing.
• Do not convey a "gotcha" attitude when observing employees. Use a behavioral checklist, and tell employees, "I'm going to watch you work and check off what you're doing safely and what's risky."
• Analyze the risky behavior you observe. In using a checklist, note the circumstances and the environment and whether factors such as excessive demands or barriers to safe behavior were involved.
• Show the employees the checklist. Geller recommends telling employees, "Here's what I found. Do you have any questions?" Do not pass judgment; do not even give advice. The focus is on asking questions and listening. "If you force change on people or are too directive, they will not internalize that change," Geller says.

Managers also need to convey that safety is not just a personal matter; when one worker is careless about safety, everybody can be in danger. "Safety is interpersonal, interdependent," says Geller. "It's depending on each other so that we all remain injury-free."

Training for employees, managers and supervisors

An effective safety management program also includes training employees and managers. The program should include the following components:

• Training so that all employees understand the hazards to which they may be exposed and how to prevent harm to themselves and others. See OSHA: Hazard Communication.
• Training to ensure that supervisors and managers understand their responsibilities and the reasons for them so they can carry out their responsibilities effectively.
• Written safety responsibilities for line managers and supervisors, plus a commitment on their part to be accountable for workplace safety and health. Staff management must play an active supporting role.
• A plan for dealing with hazards; the plan should include hazard anticipation, recognition, evaluation and abatement. To facilitate its use, the plan should provide for materials inventory, regular internal inspections and environmental monitoring, complaint investigations, and emergency procedures.
• Education and training focusing on the relevant and present hazards and on the responsibilities of management and employees in dealing with those hazards. Training in the use of relevant personal protective and response equipment should also be included.
• Review of the general duty clause and specific standards of the Occupational Safety and Health Act of 1970 (OSH Act) to ensure the proper monitoring and assessment of hazards and record maintenance.
• OSHA's requirements and state laws regarding the communication of hazards to employees and employee access to hazard data.
• Use of technologically feasible and cost-effective engineering controls, or the availability of personal protective equipment when such controls are not available.

See Training Requirements in OSHA Standards and OSHA Training: Courses, Materials and Resources.

OSHA's Susan Harwood Training Grant Program is a competitive grant process to provide training and education programs for employers and workers on the recognition, avoidance and prevention of safety and health hazards in their workplaces and to inform workers of their rights and employers of their responsibilities under the OSH Act. Organizations eligible for this program include:

• Nonprofit organizations, including qualifying community and faith-based organizations, employer associations and labor unions.
• State and local government-supported institutions of higher education

Legal Issues

Retaliation

Employers are prohibited from retaliating against employees who raise or report concerns about safety issues in the workplace. OSHA's Whistleblower Protection Program enforces the whisteblower provisions of 22 federal statutes. In the states with OSHA-approved state plans that cover the private sector, employees may file a complaint under Section 11(c) of the OSH Act or a complaint under the State's equivalent whistleblower provision or both. See What is Retaliation? and Recommended Practices for Anti-Retaliation Programs.

Safety incentive programs

Safety professionals have long been concerned whether safety incentive programs truly are a factor in reducing injuries, or if they simply encourage workers not to report when they get hurt. On Mar. 12, 2012, OSHA sent a memo to its regional administrators and whistle-blower program managers stating that organizations' safety incentive and recognition programs that reward employees for safe behavior could be violating the law. The memo explains that "while OSHA appreciates employers using safety as a key management metric, we cannot condone a program that encourages discrimination against workers who report injuries." The document details four of what the agency considers the most common potentially discriminatory safety practices:

• Safety incentive programs that discourage workers from reporting injuries. For example, the memo describes a scenario in which an employer makes employees eligible to receive a prize or bonus if no injuries have occurred in the previous year. According to OSHA, such a program, however well intentioned, may discourage employees from reporting injuries and could potentially discriminate against those who do report injuries, particularly if the employee or workgroup reporting the injury would be disqualified from receiving the incentive. This type of program could result in an employer's failure to record injuries in violation of OSHA's record-keeping and reporting requirements.
  
  

• A policy of taking disciplinary action against employees who are injured on the job, regardless of the circumstances. "An employer's policy to discipline all employees who are injured, regardless of fault, is not a legitimate nondiscriminatory reason that an employer may advance to justify adverse action against an employee who reports an injury," the memo states.
  
  
• A policy that disciplines an employee who violates an employer's rule regarding how soon an injury needs to be reported. The rules cannot penalize workers who do not immediately realize that their injuries are serious enough to report or that they are injured, the memo makes clear. Also, any discipline must not be disproportionate to the situation.
  
  
• A policy that disciplines a worker because of an injury that resulted from the employee's violation of a safety rule. Does the employer impose discipline consistently against employees who violate the work rule whether or not there was an injury? Compliance officers and whistle-blower investigators are directed to focus on whether the employer monitors compliance with the safety rule consistently in the absence of an injury and whether it disciplines for violation of the safety rule uniformly in the absence of injury. If discipline is issued only when an employee is injured, OSHA will consider such disciplinary decisions suspect.

OSHA published a final rule on May 12, 2016, that clarifies the agencies position on anti-retaliation and safety incentive programs. The final rule "(1) requires employers to inform employees of their right to report work-related injuries and illnesses free from retaliation; (2) clarifies the existing implicit requirement that an employer's procedure for reporting work-related injuries and illnesses must be reasonable and not deter or discourage employees from reporting; and (3) prohibits employers from retaliating against employees for reporting work-related injuries or illnesses."³

The final rule also implemented restrictions on employer post-accident drug testing policies. However, OSHA issued a standard interpretation in October 2018 reversing previous guidance and clarifying that post-accident drug testing is an acceptable practice. See Clarification of OSHA's Position on Workplace Safety Incentive Programs and Post-Incident Drug Testing Under 29 C.F.R. §1904.35(b)(1)(iv).

Employers considering the use of incentives in the development of a safety management program and in post-accident drug testing are well advised to consult with legal counsel before implementation.

OSHA Resources

OSHA has developed a number of resources to assist employers with developing safety management programs. Small- and medium-size employers may benefit from OSHA’s Small Business Safety and Health Handbook, which contains detailed information about various safety management programs. OSHA's Compliance Assistance Quick Start is another resource pertaining to safety management programs. In addition, OSHA's Hazard Awareness Advisor is an online tool to assist in identifying and correcting safety and health workplace hazards.

OSHA offers free, expert assistance. Compliance assistance specialists are available in every OSHA Area Office to promote cooperative programs, such as the On-site Consultation program, Voluntary Protection Programs (VPP), the OSHA Strategic Partnership Program (OSPP), and the Alliance Program. They also promote OSHA's training resources and the tools available on the OSHA website.

States that operate OSHA-approved state plans can also provide assistance, and some states may have specific requirements for safety management programs.

Finally, OSHA's $afety Pays program is an interactive expert system to assist employers in estimating the costs of occupational injuries and illnesses and the impact on a company's profitability.

Conclusion

Workplace safety and security are effective only when programs, policies and procedures achieve their stated objectives—to prevent harm to people, property and the environment. Effective practices vary depending on the scope of the specific safety and security measures.

Building a world-class safety and security program takes time, dedication and commitment. Safety and security programs have many effective practices in common. Organizations should have a written safety and security program that addresses operation-specific hazards and security threats. Management must be visibly supportive and involved, and employees must actively provide feedback and contribute toward policy formation and implementation.

Additional Resources

Samples

Accident Incident/Near Miss Report

Checklist: Employee Accident Investigation

Ergonomic Workstation Evaluation Request

Safety Policy

Agencies

Occupational Safety and Health Administration

U.S. Department of Labor

The National Institute for Occupational Safety and Health (NIOSH)

Endnotes

¹Babcock, Pamela. (2005, July 1). Safety consciousness. SHRM Online. Retrieved from https://www.shrm.org/hr-today/news/hr-magazine/pages/0705babcock.aspx

²Ibid.

³Improve Tracking of Workplace Injuries and Illnesses, 81 Fed. Reg. 29,623 (proposed May 12, 2015) (to be codified at 29 C.F.R. pt. 1902 and 1904). Retrieved from https://www.federalregister.gov/documents/2016/05/12/2016-10443/improve-tracking-of-workplace-injuries-and-illnesses