Last week, I made the point that while just about all companies have health and safety policies, precious few have health and safety policies that are really effective. Creating effective policies takes a big commitment. Why should a company undertake such a commitment? This week, I'd like to answer that question and explain what's at stake.

3 Reasons Every Employer Needs an Effective Policy

There are at least three reasons it's important for companies to create effective health and safety policies:

Reason 1: To Get Workers Involved in their Own Safety

An effective health and safety policy serves as a set of guiding principles--a playbook for everyone in the workplace to follow. When they're done right, such policies ensure that matters affecting health and safety are carried out consistently and in accordance with industry standards. They prevent things that cause accidents, such as duplication of effort, inconsistent or confusing information, and deviations from established safety procedures. They help workers understand what's expected of them enabling them to function more efficiently, with a sense of pride and purpose, and with less stress.

Reason 2: To Ensure Compliance with Legal Requirements

OHS/OSHA regulators hold employers responsible for incidents resulting in fatalities even when it can be proven that the incident was caused by a worker's deviation from company safety policies. For example, this was evident in the case of Ricardo Garcia, a Laredo, Texas, worker who died while cleaning the inside of a tanker truck. Reynolds Nationwide, Garcia's employer argued that the incident was the result of Garcia's own misconduct. Garcia had been told to clean the outside of the tanker and was not authorized to go inside. But he did anyway. OSHA still cited Reynolds Nationwide for a violation.

To comply with OHS/OSHA regulations a company must be able to prove that it has taken all reasonable steps to protect the worker. Establishing a health and safety policy is one of the key steps employers are expected to take. But the mere existence of a policy doesn't prove anything. The employer must be able to show that the policy was effective. This means documentation must clearly establish that the employer has:

• Established procedures for implementing the policy;
• Communicated it effectively to workers;
• Ensured that procedures for enforcement are in place and implemented;
• Enforced the policy and disciplined violators; and
• Adequately trained workers to do the job and given them the necessary tools.

Reason 3: To Gain a Competitive Edge

Keeping your workers safe and healthy has a major impact on a company's bottom line. Accidents are costly. They also tend to harm a company's reputation and make it harder to attract and retain competent workers and loyal customers.

Safety also affects a company's competitive position. This is especially true if you're a contractor or subcontractor. Most organizations require contractors involved in the bidding process to demonstrate their ability to effectively manage workplace hazards. Owners and project managers routinely disqualify bids presented by companies whose health and safety policies and safety performance fall short of acceptable standards.

Conclusion

Next week, I will finish my series by explaining what you can do to create a health and safety policy that is both technically sufficient and easy to read.

ASK THE EXPERT

Safety Management

By Wayne Pardy, CRSP

Editor's Note: Thank you for your questions for Wayne.

___________________

DISABLED WORKERS & EMERGENCY RESPONSE

QUESTION

Whose responsibility is it to assist a handicapped individual out of the premises in case of emergency response? For example, if an individual who works on the 11th floor can't walk down the stairs, should the company's fire warden assist the individual or is it the Fire Department's responsibility?

Laura Tysowski, Manager
Evidence and Property Unit (#616)
Calgary Police Service

ANSWER

The question of responsibility can be answered in 2 parts. First, employers are responsible for ensuring that they have a plan in place, as well as individuals with the assigned responsibility to carry out whatever tasks are associated with the safe evacuation on any facility. Having said that, I would quickly add that it behooves employers to identify a specific individual (or individuals) who have select roles to perform to address risks associated with any evacuation procedure. This can be anybody the employer so chooses based on the realities of the business, resources available to them, etc.

In answer to your specific question of whether it's the company's fire warden who assists the individual or is it the Fire Department's, my suggestion is that the company's fire warden, or another individual assigned by the employer be given this first responsibility. They would know better who is in the building and where within the building these people are located than would a fire department only remotely involved in building affairs.

*****
SAFETY TRAINING FOR CONTRACTORS

QUESTION

We have outside contractors coming in to do work on a damaged wall. We have contractor orientation training, and the company also checks to make sure the contractor employees have documentation of all of their safety training. My question: Is there any type of certification training required for operating a Bob Cat doing construction work? I know that a competent person is required but are there any other credentials required?

Pete Hastings
H&S Rep. B Shift

ANSWER

No legislation or regulations that I know of specifically reference that specific piece of equipment. But general duty clauses associated with training requirements place a responsibility on the employer and employee to ensure that whatever training is required to competently operate any piece of equipment should be addressed. If there were an accident involving the employee and this piece of equipment, a logical question for investigators/regulators to ask would be in the area of training, the amount and type of training and some evidence of competency.

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OH&S POLICY CREATION

QUESTION

I recently met a woman at a seminar who's just been assigned the task of creating a health & safety program for a growing manufacturing company with plants in both Canada and the US. She's been given three months. She has some workplace safety experience, but has never undertaken anything of this magnitude. She's overwhelmed and doesn't know where to start. Any suggestions?

Catherine

ANSWER

My opinion is that it is impossible to do this in three months (maybe I should say impossible to have it 'finished' in three months). When I say 'this', I mean to develop a comprehensive, professional safety management system for both Canada and the US. She may be able to start the process, but I don't believe it will be finished in three months to resemble anything professional. Keep in mind these systems evolve, grow and change over time as well, so it will not start and stop in three months.

My advice:

• Conduct a risk assessment
• Determine which legislation impacts your respective workplaces. Because you have plants in both Canada and the US, this will be a demanding task
• Identify at least the basic framework for the management systems, as you can add to these as they grow and mature
• Check with resources or contacts in the industry in which you are working. Many of these people already have sample programs in place and may be able to share them with you.
• Consider hiring a consultant to help with the work load
• Finally, find out why there's only a 3 month window to accomplish this, and see if you can get an extension

Start with the ANSI Z10 and CSA Z1000 as your standard for the basis of your safety program. It will save you a lot of work, will be already done for you, and will meet the test of due diligence and thoroughness.

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DOCS IN CROCS

QUESTION

I have a question for you in regards to a type of footwear that has become prevalent in our healthcare sector which does not seem to have a consistent approach by fellow safety practitioners within the healthcare industry.

My question: Are you aware of any studies or do you have a personal opinion on the use of these "Croc" shoes that seem to be everywhere. Policies which are not specific enough to prohibit their use seems to make this a thorn in the side of many managers as banning them is far from a popular stance with the workers, acknowledging that they do provide some relief for those who spend a great deal of time on their feet. They are light-weight, comfortable, breathable and affordable. However, they also do not provide the best protection against chemical or blood-borne exposure, little resistance against crushing forces and have little to no ankle support. I have no data to support my theory but I am quite sure that their rubber/foam construction would not hold up very well against some of the more common chemicals in use here in the hospital. Any ideas, support or opinions on this subject would be greatly appreciated.

Jason Raymond
Coordinator, Employee Safety, Security, Emergency Response

ANSWER

There are no studies on the safety of Crocs that I'm aware of. Here is what Croc itself says about its shoes:

1.) Really soft, super comfortable, molds to your feet
2.) Barely there, weighing only 6 ounces
3.) Vented so air passes through, keeping feet cool
4.) Non-marking slip-resistant soles*
5.) Bacteria and odor resistant
6.) Ultra-hip Italian styling
7.) Port holes allow water and sand to pass through
8.) Can be sterilized in water and bleach
9.) Easy maintenance, just wipe clean
10.) Orthotic molded foot bed for ultimate comfort and support

In terms of their use, and my own personal opinion, I would default to any risk assessment or analysis you've conducted within your facility, which would mandate something other than Crocs based on risk and exposure. In other words, are there instances/exposures/work practices where the wearing of Crocs would not provide the level of protection required by regulatory requirements covering your facility, or other legislative requirements which would make the Crocs unacceptable? In other situations in your facility, Crocs might be acceptable.

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