Confession time: When I was very green, I was hired to prepare a respiratory protection program for a city. I was given no guidance and had no clue on how to do it. I labored long and hard on this. But I didn’t do one critical thing: I didn’t find out who used respirators, why, and for what.
The program I wrote was a nice interpretation of OSHA standards. A cursory examination would show that it met OSHA requirements. It would give supervisors and employees (if they ever read it!) guidance on how to use and maintain their respirators. But it gave absolutely no guidance on what respirators were needed.
That’s a serious flaw. And it’s one that I see in a lot of safety and health programs. I just reviewed one that did a nice job of reformatting OSHA standards to make them easier to read. But it had nothing specific to the employer and it included a lot that didn’t apply.
Safety and health programs don’t need to be long. They don’t need to list the applicable standards. They don’t need to cover methods or operations that your company doesn’t do.
Instead, your safety and health program should reflect what you do. And you should be doing what your safety and health program states you’ll do. If your program states that you will train employees on electrical safety every year, even if annual training is not required, then you need to train them each year.
And your program shouldn’t just sit on the shelf. Go through it with employees and supervisors. Take a section each week or month – use that program as the basis for a toolbox talk.
Is the thought of writing your own program daunting? It probably is, because you aren’t a professional writer or a safety and health professional. It’s easier to buy a program off the shelf. Okay, do that. But read it and adjust it to make it yours. Cross out what doesn’t apply. Decide who has responsibilities for what. If it’s a decent off-the-shelf program, it might be adequate. But if you don’t make it your own, it won’t be worth any price you’ve paid.
Of course, you can hire us to develop programs for you. While that will make developing your safety and health program a lot easier for you, it won’t let you off the hook completely.