Documenting Your Program

One important part of the on-going administration of your safety program and efforts is documentation. Document your activities in all elements of your workplace program. Essential records, including those legally required for workers' compensation, insurance audits, and government inspections, must be maintained as long as the actual need exists.

Keeping records of your activities, such as policy statements, training sessions for management and employee safety and health meetings held, information distributed to employees, and medical arrangements made, is also a smart idea. Maintaining essential records also will aid:

• the demonstration of sound business management, for showing "good faith" in reducing any proposed penalties from OSHA inspections, for insurance audits, etc.
• the efficient review of your current safety and health activities for better control of your operations and to plan improvements

Writing a safety policy. A written safety policy is the beginning of any safety program. The policy statement sets the tone and indicates what the consequences will be. It does not have to be elaborate, but a written policy should reflect the following:

• the purpose of the safety program
• who will be assigned safety responsibilities and what their responsibilities and accountability requirements will be

Begin by analyzing past accidents or safety problems — if they happened before and they were not corrected, they will happen again. Next, look at your industry as a whole and then look at OSHA standards.

There are specific statements and elements your safety policy should contain. They will help to not only reflect your philosophy and the intent of your safety policy, but also give specific information and guidance to employees about safety. Your policy should contain:

• a strongly worded affirmative statement that acknowledges and supports the company's responsibility
• titles, positions, and locations of those responsible for policy design, enforcement, and modification
• a system for any employee to report violations of safety rules confidentially
• documentation that establishes that the policy was given to all employees, posted prominently, and included in policy manuals
• a statement that supervisors are held to act as agents for the company
• a statement that any deviation from known policy by supervisors will not be tolerated
• a process to address how questions are to be answered and emergencies handled
• the penalties for employees who don't follow safety rules

Implementing your safety policy. Having a policy doesn't mean that you've done enough to ensure safety. Make sure that your policy is understood and followed. To protect yourself, you'll also want to document that you have shared your policy and enforced it, in the event of an accident. Follow these guidelines to make sure that your policy is implemented and applied:

• All employees should sign a document stating that they have read, understood, and will follow the company policy.
• The signed document should be retained in the employee's personnel file.
• New employees should sign prior to actual work.
• As the policy is updated, new sign-offs should be secured.
• Safety training should be provided for supervisors and employees.
• Safety bulletins and other communications should be distributed as information changes.
• Discipline should be consistently applied to all individuals in similar circumstances.
• Supervisors should be fully advised of the impact of their actions, given special caution concerning sole reliance on verbal instructions for safety directions, and urged to provide closer supervision to workers who are known to have violated safety rules or have personal problems that may interfere with their attention to their work.
• As requested or scheduled, supervisors should perform independent inspections and follow up inspections to ensure the work areas and employees are conforming to safety rules.

The Business Tools area contains a sample safety policy for you to use. Use it to create a policy to fit your needs and requirements.

In a written safety program, accountability is the key. Some states allow for a reduction in a workers' compensation award when an employee fails to follow a safety rule or fails to use safety equipment. Safety programs should not just be written; each employee should be given a copy of the safety program and should sign to show that a copy was received. Consider including your safety policy in your employee handbook, if you have one.