Published September 2007
Proactive Safety
By Ted J. Rulseh (page 16)
The OSHA small-business consulting program is a good way to assess safety in your workplace.
Safety is largely about being proactive. And being proactive can include working with regulators to make sure you are complying with safety regulations — instead of waiting until an accident happens, or an OSHA inspector pays a visit.
OSHA has a consultation service for small businesses that can help you learn about potential hazards at your worksites, improve your safety and health management program, and even qualify for a one-year exemption from routine OSHA inspections. The service is delivered by state governments using professional staff.
The safety and health consultation program is completely separate from OSHA inspections. If the consultant should find you out of compliance in some area, you will not be cited, and there will be no penalties.
The consultation is also confidential: Any information you provide about your workplaces, and any unsafe conditions the consultant finds, will not be reported routinely to the OSHA inspection staff. Your only obligation is to commit yourself to correcting serious job safety and health hazards in a timely manner.
Better for business
Consulting is based on the idea that if you know your workplace hazards, you are better able to eliminate them — and that can only improve your business. You will get professional advice and assistance, and you and your employees will receive onsite training. The consultant can help you establish or strengthen your safety program, making safety and health activities routine.
Because consultation is voluntary, you must request it. Your phone call or letter sets the process in motion. The consultant will discuss your specific needs with you and set up a visit to accommodate your work schedule. OSHA encourages a complete review of your firm’s safety and health situation, but you can limit the visit to one or more specific problem if you wish.
On arriving at your workplace, the consultant will first meet with you in an opening conference to review the consultant’s role and your obligations. Then, you and the consultant will examine conditions in your workplace. OSHA strongly encourages maximum employee participation in this phase. Informed and alert employees are your best resource for identifying and correcting those “accidents waiting to happen.”
In addition, conversations with employees during the walk-through help the consultant identify the nature and extent of hazards.
Getting to results
The consultant will study your operations and discuss the applicable OSHA standards with you. He or she also will point out safety and health risks that might not be cited under OSHA standards, but nevertheless may pose risks. The consultant may suggest other measures, such as self-inspection and safety and health training, that can help you prevent hazardous situations in the future.
A comprehensive consultation also includes:
• Appraisal of mechanical and environmental hazards and work practices
• Appraisal of the present safety and health program, or the creation of one
• A conference with management on findings
• A written report of recommendations and agreements
• Training and assistance for implementing recommendations
The consultant then reviews detailed findings with you in a closing conference. You will learn not only what you need to improve, but also what you are doing right. At that time, you can discuss how to address any issues found during the walk-through.
In rare instances, the consultant may find an “imminent danger” during the walk-through. If so, you must correct that immediately. In other situations, which would be judged a “serious violation” under OSHA criteria, you and the consultant must develop a reasonable plan and schedule to eliminate or control the hazard. The consultant will offer general approaches and options, and may suggest other sources for technical help.
Following through
After the closing conference, the consultant sends you a written report detailing the findings and confirming any abatement periods agreed upon. Consultants may also contact you from time to time to check on your progress. You, of course, may always contact them for assistance.
Ultimately, OSHA requires hazard abatement so that each consultation visit achieves its objective: effective employee protection. If you fail to eliminate or control serious hazards according to the plan, the situation must be referred from consultation to an OSHA enforcement office. OSHA says this rarely happens.
In summary, your consultant will:
• Help you recognize hazards
• Suggest approaches to solving safety problems
• Identify sources to provide further help
• Give you a written report that summarizes the findings
• Provide training and education for you and your employees
• Recommend you for a one-year exclusion from OSHA programmed inspections, once you meet program criteria.
You can find out more about the OSHA consulting program for small business at www.osha.gov/dcsp/small business/consult.html.
