Developing a workplace program following these four points is a key step in protecting you and your workers' safety and health. If you already have a program, reviewing it in relation to these elements should help you improve what you have.
Following this four-point approach to safety and health in your business may also improve efficiency. It may help you reduce insurance claims and other costs. While having a safety and health plan based on these four elements does not guarantee compliance with OSHA standards, the approach will help you toward full compliance and beyond. It will certainly give you a way to express and document your good faith and commitment to protecting your workers' health and safety.
This approach usually does not involve large costs. Developing a health and safety protection plan does not have to be expensive and generally does not require additional employees, especially in smaller businesses. Safety and health can be integrated into your other business functions with modest effort on your part.
The key to the success of a safety and health plan is to see it as a part of your business operation and to see it reflected in your day-to-day operations. As you implement the plan and incorporate it into your business culture, safety and health awareness will become second nature to you and your employees.
Documenting Your Activities
Document your activities in all elements of the Four-Point Workplace Program.
Essential records, including those legally required for workers' compensation,
insurance audits and government inspections must be maintained as long as the actual
need exists or as required by law. Keeping records of your activities, such as
policy statements, training sessions, safety and health meetings, information
distributed to employees, and medical arrangements made, is greatly encouraged.
Maintaining essential records also will demonstrate sound business management as
supporting proof for credit applications, for showing "good faith" in reducing
any proposed penalties from OSHA inspections, for insurance and other audits, and
aid efficient review of your current safety and health activities for better
control of your operations and to plan improvements.
Safety and Health Recordkeeping
Records of sales, costs, profits and losses are essential to all successful businesses.
They enable the owner or manager to learn from experience and to make corrections for
future operations. Records of accidents, related injuries, illnesses and property
losses can serve the same purpose, if they are used in the same way. The primary purpose
of OSHA-required recordkeeping is to retain information about accidents that have
happened to help determine the causes and develop procedures to prevent a recurrence.
Injury / Illness Records
OSHA rules for recording and reporting occupational injuries and illnesses affect
1.4 million establishments. Small businesses with 10 or fewer employees throughout
the year are exempt from most of the requirements of the OSHA recordkeeping rules,
as are a number of specific industries in the retail, service, finance, insurance
and real estate sectors that are classified as low-hazard.
OSHA recordkeeping can help the small business employer evaluate the success of safety and health activities. Success can be measured by a reduction or elimination of employee injuries and illnesses during a calendar year.
The OSHA recordkeeping system has five steps:
- Obtain a report on every injury or job-related illness requiring medical treatment (other than basic first aid).
- Record each injury or job-related illness on OSHA Form 300 (Log of Work-Related Injuries and Illnesses) using the instructions provided.
- Prepare a supplementary record of occupational injuries and illnesses for recordable cases on OSHA Form 301 (Injury and Illness Incident Report).
- Every year, prepare an annual summary using OSHA Form 300A (Summary of Work-Related Injuries and Illnesses). Post it no later than February 1, and keep it posted until May 1. A good place to post it is next to the OSHA Workplace Poster.
- Retain these records for at least five years.
Periodically review these records to look for any patterns or repeat situations. These records can help you to identify high-risk areas that require your immediate attention.
Basic OSHA recordkeeping requirements address only injuries and illnesses, so you might consider expanding your own records to include all incidents, including those where no injury or illness resulted. This information may assist you in pinpointing unsafe conditions and/or procedures. Safety councils, insurance carriers and others can assist you in instituting such a system.
The employer is required to report to OSHA within eight hours of the accident, all work-related fatalities or multiple hospitalizations that involve three or more employees.
Even if your business is exempt from routine recordkeeping requirements, you may be selected by the Federal Bureau of Labor Statistics (BLS) or a related state agency for inclusion in an annual sample survey. You will receive a letter directly from the agency with instructions, if you are selected.
Exposure Records and Others
In addition to injury/illness records, certain OSHA standards require records on
the exposure of employees to toxic substances and hazardous exposures, physical
examination reports and employment records.
As you identify hazards, you will be able to determine whether these requirements apply to your workplace. Your records should be used in conjunction with your control procedures and with your self-inspection activity. They should not be considered merely as bookkeeping.
Information courtesy of the U.S. Department of Labor, Occupational Safety & Health Administration.
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