Make Time For A Safety Program Review

Jeff Anderson
From time to time, it’s important to take a step back and do an overall evaluation of your company’s safety program. Whether done internally or by an outside set of eyes, reviewing your program can help identify gaps, as well as set goals going forward. If you've found your program has stalled a bit or you're just not seeing the results you expected, a review can help to determine why. After all, the saying goes “If you do what you’ve always done, then you’ll get what you’ve always got.”
When you undertake a safety program evaluation, you want to focus on several key areas:
  • Regulatory Compliance
  • Safety Training and Awareness
  • Management Involvement
  • DOT Program
  • Communication and Feedback
Regulatory Compliance:
Safety compliance is first and foremost about keeping your employees safe and providing a safe work environment. This should be the main reason for any safety program. But let’s face it, many things simply have to be done due to regulations from OSHA, the EPA or DOT. Take time to review regulations that are specific to your industry. Make a list of those and then check against that list as you review your programs. Some things to consider would be:
  • Is a proper orientation being given to new employees? One that covers the general safety and specific safety regulations of your company’s industry.
  • Have there been any changes in your company's business since your last program review? If so, does that change which regulations apply? Have adjustments been made?
  • Are proper inspections of your facilities for regulatory compliance being done? Are they documented? Are items noted as not in compliance corrected in a timely manner?
  • Is equipment being inspected and stored properly? Are inspections documented?
  • Is all required personal protective equipment (PPE) provided and being used properly?
  • Are all reporting requirements being met?
A though review should answer these questions. A plan to address any identified gaps should be put in place quickly to ensure not only the safety of employees, but to reduce any potential regulatory activity.
Safety Training and Awareness:
Safety training is an area that usually gets a lot of attention in most companies. But have you done an evaluation of not only the content of your training, but also the effectiveness of it? And, are employees aware of the hazards they may face on the job? These things need to be reviewed at least annually and adjustments made as gaps are found, trends identified, or changes to your company's business dictate. Areas to review include:
  • Does your company's new hire orientation cover general safety requirements as well as job specific safety requirements? Is it done before starting the work? Is the training documented? 
  • Are annual safety training requirements being met per OSHA regulations (see 29 CFR Part 1910 General Industry Training Requirements)? Are they being documented?
  • Do you have a plan for monthly training topics? Are they documented? 
  • Are all employees being covered for general safety requirements such as office or maintenance staff? How about managers?
  • How is safety training effectiveness being measured?
  • Does your training account for accident trends?
Safety training is the cornerstone of any safety program. From covering the basics to job specific safety requirements to emerging hazards, your companies program needs to be broad and specific at the same time. Reviewing content and effectiveness is key to making sure key issues are not slipping through the cracks.
Management Involvement:
How involved in the safety program are your supervisors, managers and even executive team? If safety is the sole responsibility of the Safety Director, then chances are your safety program is not being as effective as it can be. Safety needs to be owned by all levels of the organization to be truly effective. 
Have safety goals and objectives been established and agreed upon by upper management and have those goals been communicated throughout the organization?
  • Does management participate in safety meetings, safety committee meetings and safety inspections?
  • Is safety an agenda item for every meeting in the organization?
  • Is safety performance and participation part of management's review?  
  • Is safety performance and participation part of management’s compensation and bonus plan?
  • Are managers holding employees accountable to safety standards set forth by the company?
  • Do managers actively participate in the accident investigation process including corrective actions?
Safety culture must be organic in an organization. If it is being solely driven by the principle safety person in the company, it will not be effective. For managers, the saying goes “if it's important to you, it will be important to your employees.” The same can be said for the opposite of this “if its not important to you, it won’t be to your employees.” Make sure that the safety goals and objectives of your organization are the responsibility of all levels of management. 
DOT Program:
If your company has a transportation component that falls under FMCSA regulations, you should include it as part of your safety program review. It's easy for your DOT program to get away from you, so at least an annual review along with regular spot checks is recommended.
Take some time to review the major areas of your DOT program including your Driver Qualification Files, Drug and Alcohol Testing Program, Hours of Service (logs) and Vehicle Maintenance program. Another area to check on is your insurance coverage. Do you have the proper amount for your business?  Review FMCSA Part 387 for more details.
Communication and Feedback:
Safety isn’t all about regulations and training, it’s also about communication. Communicating goals, standards, expectations and values are a big part of an effective safety program. As is getting feedback from employees on the effectiveness of the program. If this area is ignored, then your program will not be as effective as it can be. Some areas to look at would be:
  • Does your company have a Safety Committee and are all levels of the organization represented? Are written minutes kept and action items communicated throughout the organization?
  • Are safety alerts distributed regularly for things happening in your company, industry or related to seasonal issues?
  • Are safety goals communicated through meetings, posters and other media?
  • Is there a safety incentive program? Is it tied to company goals, as well as the individual? Is it meeting the goals?
  • Is there a mechanism for employee suggestions for improvement other than the Safety Committee? 
  • Are employees empowered to stop work if unsafe situations exist? Do they know this?
Meetings, alerts, signage and incentives all play a part in an overall safety program. Make sure these are in place and being used in your company.
Your company may have had some success in reducing workplace accidents and injuries. But don’t just assume it's due to having all your bases covered. Take some time on an annual basis to review your overall safety program for gaps before they bite you. Be proactive in keeping your safety program as comprehensive as possible.
Please post comments and questions below. Additionally, the Gibraltar Group is available to assist you with a complete safety program review including recommendations and plans for improvement. If you are interested, contact one of our advisors today.