What Is Too Much or Too Little? – 10/31/22

Safety E-QuickTips

U.S. Compliance Systems, Inc.

Monday Oct 31, 2022

What is Too Much or Too Little?

Last week’s E-QuickTip ended with me telling you I would continue to discuss how to implement your company safety program, but things got the best of me this week, and I wasn’t able to put the time into the E-QuickTip I felt it deserved.

So, I went into my list of over 500 E-QuickTips to find something we always get a lot of questions about.

Safety programs come in all sizes, from 10-50 page templates to programs that contain hundreds of pages and everything in between.

So, the question is, what is too much and what is too little when it comes to a company’s written safety program?

To answer this question, you first need to understand what you’re trying to accomplish with a company safety program.

Here’s a little information that might help answer that question.

As an employer, OSHA says you are responsible for protecting your employees from hazards in the workplace. That means you must protect your employees from those hazards that are created by the work your employees perform, as well as the work performed by others.

If you are in manufacturing or another industry, that means that even if your employee does not use a specific piece of equipment, such as a forklift, he/she needs to be protected from it if he/she is exposed to it.

And let’s not forget about that piece of equipment rarely used by the employees. If you ever use a piece of equipment in your work, even just one time, you must provide your employees awareness and training on that piece of equipment before they operate it or are exposed to hazards created by its use.

That brings us to OSHA’s Multi-Employer Policy where more than one employer may be cited for a hazardous condition. I’m not going to go into this in detail but in simple terms it says that an employer can be cited whether they are the exposing, creating, correcting, or controlling employer.

Although we see OSHA issuing more citations to contractors under this policy, those of you who have a facility and have outside services or contractors coming on your site can be cited under this policy as well.

Lastly, a company safety program should define your company’s policies and procedures when it comes to employee safety, and it should contain the necessary information to allow you to effectively communicate the information to your employees so they can protect themselves from hazards in the workplace.

With this information in mind, I find it hard to believe that the information contained in a 10-50 page template could provide a company enough information to meet OSHA’s requirements, as well as provide the employer enough information to effectively protect their employees from hazards in the workplace.

I also believe this information shows that, depending on the type of work your company performs, a program that contains up to 500 pages of safety information would not be too much. A program this long would be what is necessary to help protect your employees from hazards that are created by the work they perform, as well as the work performed by others.

Now, don’t get nervous thinking you have to try to communicate all 500 or so pages of a safety program to your employees. Remember when I said above that you need to provide your employees information on how to protect themselves from a hazard before they are exposed to it?

That’s all you need to be concerned with in your safety program today.If employees are exposed to other hazards tomorrow, you’ll have those answers when they need it.

And by the way, OSHA cannot cite an employer for having more than what they need in a program or for not providing employees awareness on those topics if there is no exposure to the hazard.

Have you just received your first Safety E-QuickTip or just want to look at past issues? Check out our Safety E-QuickTips Archive Page on our website.

Employee QuickTip

Your company’s safety program is the first place you should look for answers on how to protect yourself from hazards in the workplace.

Employer/Management QuickTip

Reviewing your company safety program every year to ensure it is up to date with the hazards your employees are exposed to is critical in preventing workplace accidents.

Have you received your first Safety E-QuickTip or just want to look at 500+ past issues? Check out our Safety E-QuickTips Archive Page on our website.

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Thanks for Reading and Please – Stay Healthy and Work Safe.