Safety Management Best Practices: OSHA’s Recommendations for Safety & Health Programs

Safety Management Best Practices Image

Back in October, 2016, OSHA created a final version of their new guideline for safety and health management programs, titled Recommended Practices for Safety and Health Programs. Around the same time, they published a helpful website full of additional materials related to best practices for safety and health programs.

In the article below, we’ll review the high points of OSHA’s new safety management guideline. And we’ll also include some links to other resources on safety management for you down near the bottom of this article.

We’d love to hear your opinions of and experiences with the new guideline in particular or with safety and health management in general. There’s a comments section at the bottom of this article–don’t be shy about using it. Also, feel free to download our free 10 Steps to Getting Started with Safety Management infographic, which is based on this OSHA document.

Please note: this article is about OSHA’s safety management guideline for general industry employers. See the following link for their Construction Safety Management Guidelines.

Safety Management: What Is It and Why You Should Use It

Let’s learn a little about safety management before we start telling you how to do it.

What Is Safety and Health Management?

So first question first: what is safety management?

You can think of a safety and health management system as something that makes your safety efforts at work forward-thinking and proactive, whereas traditional safety management efforts often look only at incidents, meaning they’re backward-focused and reactive. This is similar to and related to the distinction between lagging and leading safety indicators for safety measurement.

Here’s how OSHA puts it:

The recommended practices emphasize a proactive approach to managing workplace safety and health. Traditional approaches are often reactive–that is, Actions are taken only after a worker is injured or becomes sick, a new standard or regulation is published, or an outside inspection finds a problem that must be corrected. Finding and fixing hazards before they cause injury or illness sis a far more effective approach. Doing so avoids the direct and indirect costs of worker injuries and illnesses, and promotes a positive work environment.

Source: Recommended Practices for Safety and Health Programs (OSHA 3885), OSHA, October 2016, p. 3.

Your takeaway there is the emphasis that safety management places on being proactive.

In addition, take note of that mention of “direct and indirect costs,” because we’re going to come back to that.

Benefits of Safety Management

The primary goal of a safety and health management program is to prevent workplace injuries, illnesses, and deaths (and all their secondary consequences, such as the hardship these incidents place on employees, their families and friends, the community, and employers).

But safety management will provide more benefits than just that. Here’s what OSHA says:

Employers may find that implementing these recommended practices brings other benefits as well. The renewed or enhanced commitment to safety and health and the cooperative atmosphere between employers and workers have been linked to:

  • Improvements in product, process, and service quality
  • Better workplace morale
  • Improved employee recruiting and retention
  • A more favorable image and reputation (among customers, suppliers, and the community)

Source: Recommended Practices for Safety and Health Programs (OSHA 3885), OSHA, October 2016, p. 3.

Direct and Indirect Benefits of Safety Management

Safety management provides both direct and indirect benefits to the employer.

As an example of direct benefits, OSHA’s guideline offers these sample statistics from “a study of smaller employers in Ohio who worked with OSHA’s SHARP program to adopt safety management principles:

  • 52% decrease in workers’ compensation claims
  • 80% decrease in cost per claim
  • 87% decrease in average lost time per claim
  • 88% decease in claims per million dollars in payroll

Source: Recommended Practices for Safety and Health Programs (OSHA 3885), OSHA, October 2016, p. 3.

Those statistics are pretty impressive! But the benefits don’t stop there, and in fact OSHA claims that the financial value of the indirect benefits are greater than the direct benefits!

These indirect benefits include things like:

  • Time lost due to work stoppage
  • Time lost due to incident investigations
  • Training & other costs necessary to replace injured workers
  • Property loss and damage

According to OSHA:

These indirect costs have been estimated to be at least 2.7 times [greater than] the direct costs.

Source: Recommended Practices for Safety and Health Programs (OSHA 3885), OSHA, October 2016, p. 3.

7 Key Elements of Safety Management as Identified by OSHA

By now, you should have a good idea of what safety management is, what its primary goals are, and what are some of the direct and indirect benefits.

Now let’s take a look at what OSHA calls the “7 core elements” of safety and health programs.

1. Management Leadership

For a safety management program to work, the organization’s managers have to provide leadership, vision, and resources. They need to make it clear that safety and health are core values of the company. And they have to demonstrate, communicate, and model their commitment to safety at work.

OSHA offers four “action items” related to management leadership of a safety management program. We’ve listed and explained them in brief below.

  1. Communicate the commitment to safety and health and the safety management program
    Create a written safety management policy, have management sign it, and communicate it to all stakeholders, including: employees, contractors, subcontractors, staffing agencies, temporary workers, suppliers, vendors, other businesses in a shared facility, visitors, customers, and the community. Make safety a priority in all aspects of business, and demonstrate the same safety practices you expect from workers.
  2. Define safety management program goals
    Set goals for the program. Make sure these goals are realistic and are things you can measure (so you’ll be able to see if you’re moving in the right direction). Emphasize goals that focus on incident prevention instead of injury and illness rates (see our Safety Leading Indicators article). And finally, create a plan to achieve those goals.
  3. Allocate resources for safety management
    This includes staffing, supplies, time, and money.
  4. Expect performance from safety management program
    Make someone or some people responsible and accountable; make sure roles are well defined and understood; provide positive recognition when goals are met; and create ways for employees and management to communicate about safety and health issues with no fear of penalties, retaliation, or other negative consequences.

2. Worker Participation

A safety management program won’t work if workers aren’t actively involved and if they don’t continually participate.

Workers often know more about some job-associated safety and health hazards than management or safety personnel. In addition, they have the most at risk, and they are the operational end where the “rubber meets the road” in terms of safety.

Here are OSHA’s recommended action items regarding worker participation in safety and health management programs.

  1. Encourage workers to participate in the safety management program
    Give workers the necessary time and resources; acknowledge their contributions and provide positive reinforcement; and make it clear that worker input is welcome and valued.
  2. Encourage workers to report safety and health concerns
    Create a process for workers to report injuries, illnesses, near misses, hazards, and other safety concerns; make sure workers know about that process; make sure workers know there will be no negative consequences for reporting safety issues; provide timely feedback to employees about their safety suggestions; get workers involved in finding solutions to safety problems; and finally, allow all workers to either initiate or request a stop of work activities that they believe are unsafe.
  3. Give workers access to safety and health information
    Informed people make better decisions. This is true in safety as well. Employees will make better safety decisions if they have access to safety information–so allow them access. This can include making sure workers know where safety data sheets (SDSs) are, what they are, and how to access them; how to access injury and illness data (in some cases, redacted versions to protect people’s privacy); and results of environmental monitoring. Also consider giving workers access to workplace job hazard analyses (JHAs), safety recommendations from chemical and equipment manufacturers; work place inspection reports, and incident investigation reports (again, these may need to be redacted for privacy reasons).
  4. Involve workers in all aspects of safety management
    Get workers involved in a parts of the safety management program, including: Program development and goal setting; Hazard reporting and control efforts; Hazard analysis; Safe work practice definitions and documentation; Conducting site safety inspections; Creating and revising safety procedures; Helping to perform incident investigations (including near-misses); Developing and implementing safety training; Providing safety training to coworkers and new hires; Evaluating the effectiveness of safety training (see this article for an extensive view of designing, developing, delivering, and evaluating safety training); Evaluating the safety management program; and Participating in exposure monitoring and medical surveillance programs.
  5. Remove any barriers to worker participation in safety management program
    Watch for barriers based on language, skill, or education level; make sure enough time and resources are available; and post the 11(c) fact sheet in the workplace.

3. Hazard Identification & Assessment

A hazard is something that can cause harm at work (see our articles on the JHA and Risk Management and Safety for more on this).

According to OSHA, one of the most common root causes of injuries and illnesses at work is “is the failure to identify or recognize hazards that are present, or that could have been anticipated.” Source: Recommended Practices for Safety and Health Programs (OSHA 3885), OSHA, October 2016, p. 15.

And because of that, it’s important to identify and assess hazards. OSHA offers six action items regarding hazard identification and assessment:

  1. Collect existing information about hazards at the workplace
    Gather all existing information about hazards and review with workers. This may include (but is not limited to) equipment and machine manuals; safety data sheets (SDSs); your own internal safety inspection reports; safety inspection reports from insurance companies, government agencies, and/or safety consultants; OSHA 300 and 301 logs; reports of incident investigations; workers compensation reports; injury and illness data; exposure monitoring results; industrial hygiene assessments; medical records (redacted); current safety and health programs, including those covering lockout/tagout, confined spaces, process safety management (PSM), and personnel protective equipment (PPE); worker input; information from JHAs; information from outside sources, including OSHA, NIOSH, CDC, MSHA, trade associations, labor unions, and safety and health consultants.
  2. Perform inspections to identify additional safety hazards
    Inspect the workplace for safety hazards. Include routine inspections and job hazard analyses.
  3. Identify health hazards
    Health hazards can be less obvious and therefore harder to detect than typical physical safety hazards. Watch out for chemical hazards; noise hazards; hazards from high or low temperatures; radiation hazards; biological hazards; ergonomic hazards (this article on Industrial Hygiene may also prove helpful). Conduct exposure assessments and review medical records.
  4. Conduct incident investigations
    If an incident occurs, investigate. This article on Incident Investigations spells the process out in detail.
  5. Identify hazards that arise during non-routine situations and/or emergencies
    There are hazards that become an issue only during emergencies and/or non-routine work situations. Consider fires; explosions; chemical releases; spills of hazardous materials; startups after equipment shutdowns; non-routine job tasks; structural collapse; outbreaks of disease; weather emergencies, such as tornadoes; natural disasters, such as earthquakes; medical emergencies; and workplace violence.
  6. Characterize hazards, analyze the risk, and prioritize for controls
    The next step is to evaluate each hazard, considering the severity of the potential harm each can cause and the likelihood of each occurring. See our article on Risk Management and Safety for more detailed information on this. You’d then use that risk analysis to prioritize which hazards to control, and you’d then begin preventing and controlling the hazards (see the section immediately below).

Let’s take a closer look at hazards and hazard identification.

What Is a Hazard?

A hazard is something that has the potential to cause harm. While it’s important to remember that potential for harm, it’s also worth pointing out these three facts:

  • A hazard is not the same thing as the injury or illness itself
  • A hazard may never cause an injury or illness (even though it has the potential to)
  • Identifying hazards before they cause harm gives you a chance to remove or reduce the potential for harm

Types of Hazards

There are several different kinds of hazards. We’ve listed some categories of hazards below.

Type of Hazard Description Example
Safety Hazards Common hazards that cause immediate injuries and illnesses, and may lead to death Slip, trip, and fall hazards; working from heights; electrical hazards; moving machines; mobile equipment
Biological Hazards Other life forms that can cause injury or illnesses Viruses, bacteria, mold, fungi, animal bites/stings, toxic plants, blood and other bodily fluids
Chemical and other Exposure Hazards Things that can cause harm to you when you are exposed Radiation, temperature (high or low), noise, chemicals
Ergonomic Hazards Strains and stresses on the body caused by workplace motions and body positions Poorly designed work areas, repeated motions, lifting heavy weights
Psychological or Societal Hazards Hazards caused by interacting with people and social conditions at the workplace Workplace violence, sexual harassment, stress, depression, alcohol and drug addiction

Assessing and Prioritizing Hazards

Using tools of risk management, hazards are assessed based on their potential severity and likelihood. This helps in prioritizing which hazards to control first.

This is often done using a risk matrix like you see below.

Minor Serious Major Catastrophic/Critical
Very Likely
Probable
Possible
Unlikely
Rare

4. Hazard Prevention & Control

Once you’ve identified workplace hazards and prioritized them for correction, the next obvious step is to address the hazard to eliminate or reduce the risk. This process is known as controlling the hazard, and this phase of safety management focuses on identifying the correct control for each hazard and putting it into place.

OSHA suggests six action items for the hard prevention & control process. They are:

  1. Identify your control options for the safety hazard
    Safety standards from organizations like OSHA and MSHA, and publications from organizations like NIOSH and the Chemical Safety Board, can be great starts. Keep tabs on information from machine and equipment manufacturers, on internal engineering reports, and on information from professional safety and trade organizations, such as ASSE or NSC. Also, check with other companies and see how they control similar hazards.
  2. Select an appropriate control (or controls) for the hazard
    Now that you know your control options, choose one or more controls (to use in combination) for the hazard. Use the hierarchy of controls to make this selection (read more about the hierarchy below).
  3. Develop a hazard control plan and keep it updated
    A hazard control plan is a written plan that describes how you will implement your controls. Address the most serious hazards first, and know that in some cases temporary or interim controls may be necessary. Be sure to periodically track progress toward completing all control goals and verify that the controls remain effective.
  4. Select controls to protect workers from hazards that arise during non-routine work and during emergencies
    Create procedures to control hazards that are present during non-routine situations and emergencies. For example, how to control hazards that occur when machine guards are removed during maintenance, and how to respond to natural disasters.
  5. Implement controls
    Put the controls in place. Use your hazard assessment and prioritization to address the “worst-first” consider prioritizing controls that are easy, quick, and inexpensive as well. Always strive for completing all controls and know there’s always a legal responsibility to address severe hazards.
  6. Follow up and confirm that the controls you’ve implemented are effective
    Once controls are implemented, review them to ensure they are working and the hazard is prevented, removed, or minimized.

Controlling Hazards and the Hierarchy of Controls

Let’s take a little closer look at hazard controls and the hierarchy of controls.

What does it mean to control a hazard?

“Controlling a hazard” is the way that safety people talk about taking a hazard and either:

  • Removing its ability to cause harm
  • Reducing its ability to cause harm

So, in everyday language, controlling a hazard is a way to make the workplace safer by making a hazardous situation less dangerous.

Are there different types of hazard controls?

Just as there are different categories of hazards, there are also different categories of hazard controls. Those hazard controls are listed in the table below.

Hazard Control Description Example
Elimination Remove a hazard from the workplace Changing a production process so that a chemical known to cause cancer is no longer used
Substitution Replace a hazard with something less hazardous Changing a formula so that instead of working with a highly explosive fluid, workers work with a fluid that’s less explosive
Engineering Control(s) Design a solution that controls the hazard at its source (requires a physical change at the workplace) Encasing a noisy machine inside a sound-proof barrier
Safe Work Practice(s) Develop specific rules and procedures for all workers to follow when working in the presence of or potentially exposed to a hazard Placing warning labels on hazardous chemicals
Administrative Control(s) Developing other work practices to protect workers from hazards Limiting the amount of time workers can work in a noisy area
Personal Protective Equipment (PPE) Protective clothing or equipment that protects a worker from a hazard Providing hearing protection to people who work in a noisy area

What Is the Hierarchy of Controls?

It’s important to work through a logical progression when you’re considering controls for a hazard. That logical progression, from first to last, is represented by the hierarchy of controls.

Look at the diagram below. The hazard controls are listed in order. At the top is elimination. This is what you should try to do first. If elimination isn’t possible or feasible, then you continue down the list, trying substitution, then engineering controls, then administrative controls, and then finally (and only as a last resort) personal protective equipment.

Note: We’ve “collapsed” work practice controls into the administrative controls category here, but don’t forget about it.

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Why are the controls in the hierarchy of controls ordered in the way they are?

The most effective controls are the ones ranked at the top. Think about it–you can’t do much better than completely eliminate a hazard, can you?

Likewise, using an engineering control (such as enclosing a noisy machine inside a sound-proof barrier) is going to be better than limiting the number of hours a worker can work in the room with the noisy machine, right?

You’ll notice that the use of personal protective equipment is at the bottom of the pyramid. That means it’s the control that should be tried last. And that’s because it’s the least effective.

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Using More than One Control to Control a Hazard

Many times, you’ll find you can’t completely control a hazard by using just one of the controls.

Wha

Jeff Dalto, Senior Learning & Performance Improvement Manager
Jeff is a learning designer and performance improvement specialist with more than 20 years in learning and development, 15+ of which have been spent working in manufacturing, industrial, and architecture, engineering & construction training. Jeff has worked side-by-side with more than 50 companies as they implemented online training. Jeff is an advocate for using evidence-based training practices and is currently completing a Masters degree in Organizational Performance and Workplace Learning from Boise State University. He writes the Vector Solutions | Convergence Training blog and invites you to connect with him on LinkedIn.

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