dance records. Also, keep some record of the training content that was delivered. Training can be accomplished in fifteen minutes per topic in some cases. Some trainings require more time and experienced trainers, such as forklifts, aerial work platforms, scaffolding, competent persons, etc. I recommend train-the-trainer for cost effectiveness.
Develop your OSHA log. Remember if you have eleven or more employees you are required to keep an OSHA 300 log and post an “OSHA 300 A” between February 1 and April 30th each year. A basic rule of thumb is that if you have an injury which is “beyond first aid,” it must be recorded on your OSHA 300 log. Start your log each year even if you have no injuries. Injuries must be recorded in your log within seven days. This is known as “recording,” and such injuries are called “OSHA recordables.”
Employers of any size must report to OSHA any worker fatality within 8 hours and any amputation, loss of an eye, or hospitalization of a worker within 24 hours.
Leadership showing that the first order of business is everyone’s safety carries a powerful message. This has significant advantages for your entire organization in multiple ways. One example is on how a company responds to OSHA’s requirement that a Personal Protective Equipment (PPE) assessment be done to determine what kind of PPE is required for each job classification.
Perhaps your company has determined you need hard hats, high visibility clothing, substantial work boots (not necessarily steel toes), safety glasses, hearing protection in over 85 decibels of noise, and fall protection when working over six feet (as required by OSHA). Then you, as leadership, furnish all of the above—except, maybe, the foot protection. You also make sure that everyone on the job is wearing it, no exceptions, when required (such as fall protection or hearing protection). If you are the GC or a management oversight firm such as an engineering or architectural firm, assure all contractors and subs are wearing the same—no exceptions. Always “trust, but verify.”
You, as leader, must wear the same equipment when on the job to set the right example. Also, point out any violations to your supervisors on the job and have them correct it. Definitely hold your leadership accountable!
This can go a long way to effectiveness, thereby saving you big bucks! We live in a very litigious society. Even if you are insured to cover the cost of a lawsuit over an injury, subsequent increases in your workers compensation premium could put you out of business. Or if you aren’t adequately insured, even “simple” injuries can cost into the hundreds of thousands of dollars—and something severe into the millions. And just because it happens to a subcontractor, it doesn’t mean that you couldn’t be held liable.
Finally, I like to keep things as simple as possible, Forrest Gump being my hero. In construction, OSHA inspectors doing programmed inspections are instructed to “focus” on “Focus Four” for construction inspections. OSHA commissioned a study that showed that 89% of construction accidents were the result of accidents in one of four categories: Falls (#1), Struck-By, Caught Between/In, and Electrical.
I train my construction clients to be efficient in these areas. Be able to prove physically and by documentation that these areas are being covered in their safety process and on the job. Examples:
•• Falls—ladder safety; personal fall arrest systems (body harness) when needed; guardrail, mid-rail, toe board when possible.
•• Struck by—high visibility clothing; hardhats; safety glasses; back up alarms on equipment.
•• Caught between/in—lockout/tagout equipment and training; excavation training; confined space training.
•• Electrical—GFCI’s in use on all extension cords; no exposed energized circuits, training, no tape to repair extension cords, ground pins in place.
Be sure to have training records available in these areas and document periodic inspections of the same.
Finally, my company teaches that, “the best defense is a good offense,” when it comes to safety and OSHA compliance. Being reactive can drive you out of business. Front-end emphasis and investment along with setting great leadership examples allows you to focus on successful building, which is what you do. Plus, what better thing is there than showing your employees that their safety is truly the top priority of your business!
John Nain, Owner, Nain and Associates. Nain provides safety training, safety monitoring, OSHA compliance, and accident mitigation services to business owners, including those involved in residential construction through heavy industry construction, as well as to engineering and architectural firms. He works primarily in the southeast U. S. and uses his 30 years of experience as a safety professional and 10 years of experience in owning a business to bring a “real world” perspective to the subject.