In order to be in compliance is OSHA, 3rd party auditors like ISNetworld, and other governing agencies, contractors need to have a comprehensive safety program manual in place. The contractor safety manual should flow down to all sub-contractors throughout the scope of the project. Many sub-contractors may already have a safety program in place, but some may not, and some may have insufficient or out-of-date safety manuals that do not fully address all aspects of ensuring employee safety. Having a contractor safety manual in place should cover all aspects of worker health and safety for all jobs being performed across the project.
Conducting a Contractor Safety Compliance Audit
The most effective safety programs are proactive in nature. Contractors should be aware of all work activities that need to take place in the development of a project, which puts overall project safety squarely on their shoulders. The process of developing a safety program in itself can help catch potentially dangerous situations prior to them becoming an issue. Whether it is equipment or process improvements, additional PPE, or elimination of hazards, it is important that these are audited on a regular basis. If there are preventable health and safety risks, they can be addressed, corrected, or improved ahead of the work actually being performed. Ongoing safety compliance audits should become part of any business with high hazard equipment, processes or environments.
The Importance of a Contractor Safety Program
According to OSHA, contractors and subcontractors are deemed to have joint responsibility for the work being performed (1926.16). Subcontractors are only responsible for their respective tier of work; however, a contractor will be responsible for all activities that take place across the entirety of the project. Thus, a contractor should incorporate the development of a comprehensive safety program manual into the planning stages of the project. Keeping safety in mind throughout the duration of the project helps ensure workers remain safe, the project is in compliance with OSHA, & limits contractor liabilities.
Developing a Contractor Safety Manual
There are 3 main components in developing a contractor safety manual:
- Compliance with OSHA laws
- Providing a workplace free of serious recognized hazards
- Examining workplace conditions to ensure compliance
OSHA compliance begins with implementing OSHA Standards that address known major hazards that may exist in the workplace. OSHA compliance also requires accurate record-keeping of any workplace incidents that affect the health and safety of employees, known as OSHA 300 logs. These logs record any injuries or illnesses caused in the workplace by potential hazards, and corrective actions that need to be taken to prevent a violation from occurring again. The key here is to be proactive and take all potential hazards into consideration while a contractor develops a health and safety program that complies with OSHA laws.
All contractors, industries, and businesses engaged in performing potentially high hazard activities that may result in injury or illness to an employee need to take the appropriate steps to evaluate their business processes and operations in order to develop an appropriate health and safety program to be compliant with OSHA laws. This should be a time-intensive endeavor that a contractor undertakes in order to provide a safe work environment for their subcontractors and their employees. Any oversights in the audit process could lead to OSHA violations, employee injuries, legal fees, insurance costs, and other issues.
Any OSHA compliance audit should begin with a thorough identification of potential physical hazards present in the workplace. These hazards should be addressed and remediated at that time as they pose the greatest immediate threat.
Develop customized health & safety manuals containing any applicable OSHA Standards with modern and relevant updates. Research outside sources such as the National Security Council, ANSI, and other safety regulatory bodies relevant to the hazard present in the workplace for the most up-to-date information and guidelines.
Develop health and safety training protocols and procedures that are customized to your operations. Training should be conducted by a competent trainer, and should be done at the time of employee hire, and at least annually for all employees exposed to the specific hazards. The training process should be time-consuming, taking 30-60 minutes per topic, or longer if required, to ensure proper training has occurred.
Developing a Contractor Safety Manual
Many contractors decide to enlist the help of outside resources to save precious man-hours and eliminate any potential oversights that may be missed if done strictly internally. The process of developing a comprehensive contractor safety program manual is a time-consuming process, and can be an overwhelming responsibility for businesses large and small. Working with a safety compliance service company like 1 Stop Compliance can help you identify workplace hazards and develop the appropriate contractor safety program to ensure you are in full compliance with governing safety agencies like OSHA.