five critical steps can help improve safety and avoid costly OSHA citations. Here’s what she recommends:
- Conduct an internal safety and health audit under attorney-client privilege. Working with an OSH professional, employers should closely examine every aspect of the workplace to ensure that they’re in full compliance with OSHA standards and best practices.
- Create a strong safety culture. Management at all levels should be involved in creating the culture by actively communicating with employees and being physically present where employees work. Make sure employees know that safety is a priority over production and that suggestions for improvement are welcome at your place of business.
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- Make sure safety and health documentation is current and well communicated. Every employer should regularly review its OSHA documentation requirements, including recording of work-related injuries and illnesses, as requirements change from time to time. Also, make sure relevant employees fully comprehend the documentation, know how and when to use it, and understand the reasons for maintaining it.
- Conduct regular and comprehensive training. Train employees regularly and comprehensively. OSHA does not hesitate to cite employers for failure to train, but Butera says this is an avoidable problem. Also, make sure you’re training in a way that employees can fully comprehend, as the law requires. One way to do this is to give a quiz at the end of training that requires employees to demonstrate their understanding. If employees are unable to reach the expected score on the first try, retrain and give the quiz again. Keep all records of training as well as quizzes and other materials.
- Protect contractors and temporary workers, too. OSHA has instructed its compliance officers to expand the scope of inspections to include temporary workers. This instruction led to a 322% increase in inspections involving temporary employees in 2014.
Read Butera's full piece at OSHA Law Update.