Programs, Policies, Manuals, Procedures, and Training

Paul Chamberlain Columns, Fall 2020 Columns, Safety Corner

Many regulatory agencies direct which documents are required to perform a company’s tasks. In some cases, federal and state requirements must be adhered to for the same task or hazard. For example, the United States Environmental Protection Agency (US EPA) and state environmental agencies, such as the Massachusetts Department of Environmental Protection (MA DEP), regulate potential environmental impacts that may occur while performing a task.

Currently, with the ongoing COVID-19 pandemic, companies must protect their workers using additional guidelines, such as those from the Centers for Disease Control (CDC). Workplace safety guidelines under COVID-19 also are available from the United States Department of Labor and their sub-department, the Occupational Safety and Health Administration (OSHA).

Currently, 22 states have a state-approved occupational safety agency that is their own version of OSHA:

  • Alaska
  • Arizona
  • California
  • Hawaii
  • Indiana
  • Iowa
  • Kentucky
  • Maryland
  • Michigan
  • Minnesota
  • Nevada
  • New Mexico
  • North Carolina
  • Oregon
  • Puerto Rico
  • South Carolina
  • Tennessee
  • Utah
  • Vermont
  • Virginia
  • Washington
  • Wyoming

This article explores the typical safety documents required to comply with federal OSHA standards. Each company must familiarize itself and comply with any additional regulations that apply to their business.

Guidelines

OSHA provides guides to developing safety programs that are dependent upon whether the requirement is applicable to the work being performed. These guides can be found at OSHA.gov.

In addition to the CDC guidelines to minimize employee exposure to the current COVID-19 pandemic, OSHA has its own guidelines. More information can be found at www.osha.gov/SLTC/covid-19/. Although OSHA guidelines are not considered law, if OSHA suggests you do something, it is generally advisable to do it. Appendix 5, the General Duty Clause, addresses when a company should protect employees from a known hazard using commonly known guidelines. Specifically, 29 USC 654 states:

(a) Each employer —

  1. shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees;
  2. shall comply with occupational safety and health standards promulgated under this Act.

(b) Each employee shall comply with occupational safety and health standards and all rules, regulations, and orders issued pursuant to this Act which are applicable to his own actions and conduct.

Job Scope and Location

It is important for a company to know its scope of work and where the work is occurring prior to developing a program, policy, plan, or procedure, and the training that goes with them. Requirements change depending on where the work is conducted. For instance, work performed in a construction setting may not have the same requirements as work performed in a general industry setting. Additionally, not all the OSHA requirements may be applicable. For example, if the company performs entry into enclosed spaces only, and does not enter into confined spaces that require a permit, the program must indicate such and training would have to include that information. The program would not need to cover entry into permit-requiring confined spaces, even though enclosed and confined spaces are found in the same OSHA regulation.

Job Hazard Analysis

A job hazard analysis (JHA) is an important tool for analyzing the work to be performed and the hazard associated with each step in performing the work. Companies should take the time to create JHAs to better understand which hazards their employees will encounter. In some instances, such as in construction, a JHA will be required per OSHA. JHAs can be known by many other names, including job safety analysis (JSA) or even just hazard analysis (HA), but they all have essentially the same outcome: identification of known hazards associated with the completion of a task. Some pre-job briefs — if detailed enough — can be considered a suitable substitute for a JHA.

Once a JHA has been completed, the known hazards will be identified. The completed JHA should be reviewed with all personnel performing the work. Once a hazard is identified, the appropriate OSHA regulation can be located to aid in creating a program, policy, procedure, or training.

  • Policies can be short and to the point. Think of these as a description sheet for a task or hazard. It is a position statement on how a company will address any issue, whether it is related to safety, environmental, procedural, or even human resources. It is usually not heavily detailed, although it may be if the topic can be covered succinctly, and will reference other pertinent information. For example, a policy for respiratory protection may only state that the company provides the respirator, training, and when wearing the respirator will be necessary. If a topic requires greater detail, it will usually be encased in a procedure or program. Policies may outline who and when, but are not detailed when it comes to how it will be accomplished. They may also speak to what can occur should a task not be completed as required.
  • Programs are designed for extensive detail. Think of these as a detailed instruction sheet, including components necessary for construction. A program highlights the requirements as set forth by the regulatory agency and reviews the training. It will get into the specifics of who, what, where, when, and why. The program highlights the documents (i.e. inspection forms) that must be filled out to comply with the regulations. Programs can be extensive, and often mimic a regulation line-for-line to ensure compliance. For example, a program goes over what employees are required to do, where they can find information on performing the task, and how to remain in compliance with the requirement. It also reviews what the company is required to perform to maintain compliance with the regulation. Each applicable hazard will usually have its own program. To continue the example, a respiratory protection program will detail the training provided, what areas require a respirator, which types are used, how to determine a respirator is required, and how a respirator is issued to an employee.
  • Procedures are task oriented. Think of these as the detailed steps in a set of instructions. They are very specific for each task performed. Procedures reference requirements as stated in programs and give physical direction line-for-line on how a task is to be performed. Procedures generally discuss the hazards associated with each step of performing the task. Continuing the example, a program on how to clean a respirator will state that respirators will be cleaned daily. The procedure will tell the employee in detail HOW to clean the respirator.
  • Manuals provide a general overview. These are usually designed as a reference for the programs. In this instance, they may only contain the information pertinent to how the employee will comply with all of the company’s requirements. In some cases, a company may replace individual programs with a manual, essentially making the manual a collection of programs — each chapter becoming its own program. This depends on how much information must be relayed. If the chapter is extensive, or the regulation the company is attempting to comply with contains requirements that do not apply to all of the company’s tasks, it would make sense to summarize only the information critical to how the company will comply in the manual. A separate program would detail the specifics on what is required to be complied with and what is not, and why. Continuing the previous example, if the employee is required to use a new respirator, the manual may just tell them where to obtain one. Details as far as types used or requirements for type used may be contained in the program.
  • Training must cover all information the employee will need to know in order to prevent the hazard while performing the task. The employee is not required to review the applicable programs, but some companies choose to perform training in this manner. Since programs are constructed similar to the regulation they are written to comply with, this can be pretty boring. Therefore, some companies choose to train using other methods, including a presentation, video, or even just on-the-job training (OJT). However, the company must ensure the employee is competent enough to perform the task prior to performing the task. Competency may need to be refreshed on a regular basis, dependent upon regulatory requirements. To document competency, a company can choose to use quizzes, tests, or just simple sign-off sheets indicating the employee reviewed and understood the information. No matter how training is conducted, documentation must be performed and must be maintained in a file so long as the employee works at that company.

Conclusion

Companies must comply with many regulatory requirements. A company may choose from many ways to go about complying with those regulations, but no matter HOW a company chooses to comply, it cannot avoid the eventual paperwork and documentation that must be created to reach compliance. A JHA is a good starting point for determining which hazards are present performing the job. Once the hazard is identified, it is easier to identify the regulation created to mitigate the hazard. Once a company fully complies with the regulation and relays those requirements to the employee, it will go a long way to preventing injuries. After all, knowledge is power. The more an employee knows about a hazard and how to mitigate it, the less likely he/she will be injured by that hazard.

References

Centers for Disease Control. www.cdc.gov/coronavirus/2019-ncov/index.html.

Occupational Safety and Health Administration. www.osha.gov/dcsp/compliance_assistance/sampleprograms.html.

Paul Chamberlain has been the Safety Manager for American Electrical Testing Co. LLC since 2009. He has been in the safety field for the past 17 years, working for various companies and in various industries. He received a BS in safety and environmental protection from Massachusetts Maritime Academy.