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Don’t Allow the Latest OSHA Scuttlebutt to Change Your Focus

Here we go again, everyone is talking about how tough OSHA is making it for companies, and I happen to agree with them, but let’s get real here.  OSHA is a political environment just like the safety department is in most organizations.  Why?  Because lives are at stake and everyone wants to save lives and prevent injuries, and everyone has an opinion about how to do it, especially those trying to get re-elected or elected.
Jim Collins, author of Good to Great recently wrote about his latest research around successful companies.  He noted that companies successful in good and bad times are those who stick to specific plans that work.  The simpler the plan, the more likely it works.  That is why I spend much of my time teaching what I believe is the foundation for a safe environment, hazard recognition and control among other safety topics.  In fact, in a few hours I will be heading to a U.S. Coast Guard Station to train some of the USA’s finest men and women in recognizing, evaluating, and controlling hazards.
When OSHA inspects your facility they have their eyes-peeled for hazards and not necessarily to see if you are compliant with the regulations.  You can be compliant and still have hazards in the workplace.  This will lead to a citation using the General Duty Clause.  To recognize all the possible hazards you must have a SMP (Safety Management Process) that recognizes, evaluates and controls hazards.  In our book ZERO! Responsible Safety Management by Design we outline what a SMP should look like, so that you can self-assess it for yourself although we assess many worksites as a third party.  We call it CSE (Criteria for Safety Excellence) because as a consultant, we name our product, but anyway you look at it, the best process (or program if you choose) looks like, acts like and works to recognize, evaluate, and control hazards.
I remember my Dad saying, “If it walks, flies and quakes like a duck… it’s a duck.”  Assessing your SMP is what OSHA is going to do when they come in.  If you can show them a process that is uniquely yours and it recognizes, evaluates, and controls hazards like a SMP is suppose to do… then it’s a SMP.  Ultimately, your SMP should effectively prevent injuries and deaths in the workplace.
If we recognize, evaluate, and control hazards in the workplace then we should see a reduced number of incidents.  Less incidents lead to less accidents.  Focus on your SMP and not what OSHA is going to do to you.  As safety professionals we work for the employees and their families, not OSHA.  Our goal should be to create a safety culture where everyone takes personal responsibility for safety, so the nobody gets hurt.
Maybe in my next post, I will discuss incident prevention.
Be Safe!
Carl Potter, CSP


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