OSHA Ramps Up (CONT’D FROM PAGE 1)
Some companies schedule these at the beginning of ev- ery shift. Getting Specific OSHA will look for policies and practices that are site specific, noted Gary Heppner, a Cherokee, Kansas-based independent OSHA safety advisor. “An inspector typically goes into a shop, removes guards from a drill press, and then picks somebody at random to set up the press and drill an obscure hole in the metal. The employee’s actions must reflect training specific to that machine.” It’s not good enough, added Heppner, to just download some safety boilerplate from the Internet. “If OSHA sees that a company’s policies are too general they may well do a fishing expedition to find out what is lacking in the program.” Once the specific policies are in place, it’s important to perform ongoing monitoring, said Foulke. “As the eyes and ears of the company, supervisors should walk the floor during the workday, not only checking the production line but also making sure people are not violating safety rules. Are they wearing their personal protective gear? Working the equipment properly? The supervisor should fill out a form that records what inspections were done and what actions were taken when violations were identified.” Obtaining Feedback These regular workplace tours provide excellent oppor- tunities to obtain feedback from those on the front lines.
employment law firm of Bracewell, Houston. “They could be a contractor, a vendor, or a member of the public. In such cases the company does not have the protective bar- rier of workers’ compensation insurance against a lawsuit for full and punitive damages.” Leading The Way Now is the time to double down on protective policies and procedures. Everything starts at the top of the man- agement pyramid. “If mid-level managers and supervisors don’t perceive an emphasis on safety from upper manage- ment, it’s much less likely they will take the topic serious- ly,” said William K. Principe, partner in the Atlanta office of Constangy, Brooks, Smith & Prophete. “And it’s their com- bined efforts that will create an accident-free workplace.” What starts at the top, though, must filter down through the ranks. “From a legal perspective, a business operates through its managers and supervisors,” said Nichols. “What they do or don’t do is often imputed to the employer.” As the first line of defense against OSHA penalties, su- pervisors have to ensure that rules and regulations are ap- plied throughout the workplace. “New hires must be prop- erly trained from a safety perspective before they begin work,” said Nichols. Existing employees must also receive appropriate periodic and updated training. That can occur through monthly or weekly safety orientations, which are sometimes referred to as ‘toolbox’ or ‘tailgate’ meetings.
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