Top Training Challenges: How do you become OSHA compliant?
The following is an excerpt from our on demand webcast, Troubleshoot Your Training—Live!, hosted by Chief Safety Officer Jill James and Dr. Todd Loushine.
Dr. Todd Loushine:
Okay, so this is a common question and it's not a simple, straightforward one either because the OSHA regulations apply based on what your hazard potential is. So you first need to get an understanding of your company's hazard potential. Some people now are using the term risk. Risk is simply probability of exposure multiplied by the severity of the outcome. It adds sort of a more numeric or quantitative element to what is typically a qualitative from a hazard perspective. Anything you can't eliminate, anything that can possibly hurt a worker that you can eliminate becomes a safety program, and so therefore you have to look to the standards as a minimum requirement for what you need to do to control the risk for hazard.
The OSHA website has a lot of information but to be able to get into the website and play around and find the information you need is where you really need to start with OSHA compliance. The way, as a former compliance officer, Jill, you can back me up on this or not, or comment on it, the compliance officer is just trying to find out, "Okay, so you're running a company, what hazards have you identified in your workplace? What have you done to try and control or mitigate those? How are you tracking your efforts? How are you tracking the training? How are you ... What sort of incidents have occurred and what have you done post-incident? What do the workers think of the safety program? Did they understand it?"
That's what we're trying to do. It's like a pop quiz and so if you take it from that perspective, it really starts with understanding, well, your workers, your risk profile of the company and what sort of continuous improvement process you put in place for the safety program. So don't view OSHA as the enemy. They're a resource. Jill?
Right. So if you're new to this field of safety and you're like, "Where do I even start?" The two basic areas to remember and look at are what sort of programs, procedures, policies do I have to have in writing according to the law for using OSHA as the baseline, as the minimum requirements as Todd said and then what do I have to be training my employees on. Then you look at all the OSHA regulations and go, "Oh my gosh, do I have to do all of that? Like do all of them apply to me? How do I find out?"
So if you're new in this, one of those ways is to partner up with someone who can maybe do some teaching for your and that's where your insurance companies can come in, where you can invite them into your workplace to help you do an assessment, do an audit, say, "I need help figuring out what I need in writing, what policies, what sort of hazards do you see that I'm missing," so that you have someone to collaborate with. The same thing with training. So that's one way to do it. If you work with your workers compensation company or your property casualty insurance company, they often have safety people who will be able to do some kind of audit like that for you so you can set that baseline as well.
Todd and I both started our careers with OSHA. Way back when when we were doing that, we were taught how to read the regulations and back then, before the internet, it came in the form a big old book and we were asked to get like six different highlighter markers of different colors and we were taught how to read them. So we come at this from the perspective of understanding how to read the regulations which when you're looking for training and you're looking for policies, they're not very hard to find if you know how to read it.
Todd and I have been talking about we need to create an asset, some kind of video that shows people how to read them. So stay tuned. That's on our list of things to collaborate on that we can help people with as well.