Wholesale adoption of GHS hazard classsification principles will disrupt chemical hazard assessment programs and heighten problems manufacturers and importers will face.

Engage Employees in Dusting Off Safety Plans and Procedures

Reviews uncover revisions that will need to be made, procedures that will need to be updated, and training that may need to be changed.

OSHA's adoption of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) forced facilities to pull their written plans off the shelf and take a fresh look at how they comply with the Hazard Communication regulation. New, standardized labeling requirements and Safety Data Sheet (SDS) elements changed the wording and even the scope of some hazard communication compliance plans and also brought about the need for some fresh training.

Updated SDSs are arriving at facilities now. By the end of the year, manufacturers of hazardous chemicals must have old stock rotated and will be able to ship only products containing the updated warning and precautionary statements, pictograms, and signal words on product labels. (Employers have until June 1, 2016, to make sure all labels on products used in house are up to date with GHS requirements.)

It's okay to breathe a sigh of relief and set the hazcom binder aside for a moment. But workplace safety doesn’t begin and end with the hazard communication standard. Now is a good time to get everyone involved in reviewing other safety plans, procedures, manuals, and training to make sure that they are also up to date.

Top Priority
Employee manuals that are passed out to new hires on their first day of work often contain a cursory phrase that expresses something to the extent of, "Your safety is our top priority." Workplace safety doesn't happen just because a version of this statement appears in the manual. A lot of good, thorough planning, training, procedures, policies, and regular reviews are needed to back up a statement like that.

Having an abundance of written safety plans tucked securely in the back of the human resources office, hours of outdated safety videos in the training room, and faded safety posters in the break room don't cut it. Safety plans aren’t like fine wine that, when left alone, gets better with age. They're more like an expensive Swiss watch: If they are to operate at their best, they need regular attention.

Identifying Hazards
As with all safety efforts, chemical and physical hazards need to be identified before plans are created. But because new technologies and strategies for identifying and eliminating hazards are continually discovered, developed, or refined, chemical and physical hazards should be reviewed often and plans updated to reflect newer, safer ways of doing things.

Many OSHA regulations require plans to be reviewed only when something changes or at regular intervals, such as annually or every three years. A lot can change over the span of a day, let alone a week, month, or year. Often, changes are small and are easily overlooked, especially in facilities that don't have a good plan in place for auditing and regular inspections. This is one reason why OSHA requires plans to be reviewed regularly. All of those little changes that have been missed will come to light. This is also why plan reviews always seem to take longer than expected. Reviews uncover revisions that will need to be made, procedures that will need to be updated, and training that may need to be changed.

Routine inspections and audits can help to make sure that plans stay on track. The findings from inspections and audits can drive plan updates in real time–not allow them to be held for the regularly scheduled plan review.

Recruit safety committees to review inspection and audit findings. Have them identify whether or not safety plans need to be changed as a result of the findings. Safety committees also can help to review multiple safety plans to identify elements that are redundant or conflicting.

Reviewing Procedures
If the Standard Operating Procedures (SOPs) documented in a safety plan look like they were written by a lawyer and sent through three online language translation services before they hit the paper, it's probably time to review them, as well. They may look nice, but if they're not realistic and don't reflect what employees are actually doing, they may not do enough to keep everyone safe. They can also create compliance issues during OSHA inspections.

In OSHA’s hierarchy of controls, SOPs are forms of administrative controls. As such, they need to be clear and concise if they are to be effective. Well-constructed SOPs should allow someone who is not familiar with a process to be able to follow the instructions to complete a task safely.

Enlist the help of machine operators and others who directly perform hazardous tasks to review and rewrite work procedures and SOPs. One way to start is for them to simply list the steps they currently take to perform a task, then look at what the existing SOP says. Where there are differences, have them determine which is safer and ensure that the updated version is documented in plans and manuals.

Although safety videos are convenient and allow the "annual training completed" box to be checked off, it's hard to engage adult learners with a safety video that they've already seen a dozen times. Even worse, if things have changed, anyone who does manage not to fall asleep may be viewing information that is out of date and no longer reflects safe practices.

Very few employees look forward to safety training because, traditionally, it’s boring. Whether it’s a worn-out video or a deck of slides that show entire paragraphs copied straight out of the Code of Federal Regulations, if training doesn’t stimulate learning, the time that everyone is relegated to a meeting or training room is poorly spent.

Like production employees reviewing SOPs and using safety committees to look for paragraphs that need to be changed in written plans, updating and refreshing training materials is another area where employees can be involved in creating something better. Pair up new employees with long-timers or create groups comprised of individuals who wouldn't normally get a chance to work together to develop and possibly deliver routine safety trainings. Provide them with a set of learning objectives but allow them the freedom to use different types of instruction, such as games, posters, video clips, pictures, or other methods to create something new that is more appealing than a stale, compliance-oriented lecture. Chances are, they'll learn something new and everyone who needs to be trained will appreciate the change of pace.

Safety plans acknowledge workplace hazards and outline the steps that need to be taken to avoid employee injury, illness, or death. Involving safety committees and other employees in reviewing plans, procedures, and training materials will ensure that they remain up to date, reflect current practices, and truly help to improve safety in the workplace.

This article originally appeared in the May 2015 issue of Occupational Health & Safety.

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