I recently came across an article in Construction Executive, by Edwin Foulke, listing 13 ways to improve your OSHA compliance record. Mr. Foulke is a prolific writer and presenter on occupational safety and health issues, and author of the Workplace Safety and Health Law Blog You can find a copy of his article here.
Although Mr. Foulke’s article mentions 13 actions that can improve your OSHA compliance, a few of them stood out to me.
Develop an overall safety plan. Although OSHA does not presently require a written comprehensive safety plan, it does require that supervisors be trained in specific hazard areas. Employers would be well advised to create a overall safety strategy to not only train supervisors, but to also review your safety practices to ensure they are up to date.
Understand OSHA’s Multi-Employer Citation Policy. All contractors on a worksite should understand that more than one employer may be cited for a hazardous condition that violates an OSHA standard. This concept is particularly applicable where one employer creates a hazard that causes harm to another employer’s employee.
Comply with OHSA’s record keeping requirements. OSHA’s compliance officers are paying close attention to employers’ record keeping practices, particularly the OSHA 300 Logs—the log of work-related injuries and illnesses. Employers would be well served to review their last several years of logs to make sure that they accurately reflect all injuries. It’s so much easier to review them now instead of reviewing them with an OSHA compliance officer.
These are just three highlights of Mr. Foulke’s excellent article. I recommend you review all 13 points he raises to improve your OSHA compliance efforts.