4 Workplace Inspections to Maintain Your Safety Program
Your safety plan must be a living, breathing document. All too often, a company will pay a consultant to develop a program or download a cookie-cutter template off the internet to satisfy some contractual requirement, then do absolutely nothing to implement that program or foster a culture of safety within their organization. This, of course, is doing nothing to prevent injury to your employees. In order to be successful safety-wise, you not only must implement any procedures contained within your plan, but you also must do program maintenance to ensure that everything is working as well as it could. So, what does program maintenance look like?
1. Periodic Inspections
Creating specific procedures – and training your employees to follow those procedures – does nothing if you’re not checking to see if they’re being properly implemented in the field. While you can’t be at every job site, every minute of the day, you can perform spot checks. Every time you, or any other member of your management team, set foot on a job site or the facility floor is an opportunity to see if your program is working effectively. Look around. Are your workers doing things the way they are supposed to? Are they wearing the proper PPE? Does the work look safe?
These inspections shouldn’t just be left to chance either. Schedule periodic inspections. Ensure that qualified people are the ones being assigned to perform them. Make sure that findings are addressed, then look for trends. Just finding a quick fix to a violation is putting a Band-Aid on the problem if the violation isn’t an outlier. If it’s happening repeatedly, you need to determine if that’s caused by a lack of training, a poor safety culture, some other reason, or a combination of these.
2. Equipment Inspections
It’s not just your people that need to be inspected, it’s also your equipment. People are only as good as the equipment they are using and that leaves a lot of opportunity for failure. From harnesses to ladders to forklifts, everything that gets used should be inspected. Determine an inspection procedure, develop forms that are clear and easy to use, but still gather all the necessary information, and train your employees on how to do the inspections properly.
Some, of course, will need to be done by specially trained people, while other things will be able to be inspected by the user. For instance, a user can do a quick pre-use inspection of their fall protection equipment, but periodic inspections should also be done by a Competent Person (as defined by OSHA). Forklifts can be inspected pre-use by the operator, but preventative maintenance and inspections should be scheduled to be performed by a mechanic.
Determine the frequency of inspections. Some level of inspection must be done every time a piece of equipment is used but documented periodic inspections may also need to be done less frequently. A good example of this is a crane. A crane should be checked daily by the operator, but also should have documented periodic and annual inspections.
Research the regulatory requirements to make these determinations. Don’t hesitate to reach out to a consultant, distributor, or manufacturer to ensure you have the right answers.
3. Inspections of Procedures
While all procedures need to be reviewed to ensure that they are effective, some have specific regulatory requirements to do so. For example, Lockout/Tagout procedures must be reviewed at least annually. This means that you must witness the procedures in action, note any shortfalls, and implement new procedures to address those shortfalls.
It is very important that you document these reviews and your findings, even if your findings were that everything was working perfectly. Keep a log of the times that you reviewed the procedures, who reviewed them, what your concerns were (if any), and what is being done to address those concerns. Make sure your health and safety plan is dated every time you revise a procedure. If you make no revisions, make sure you still update the date to show that the policies were reviewed.
4. “Inspections” of Employee Competence
You need to designate Competent Persons for many different things, per OSHA. A Competent Person is defined as one who has the knowledge to recognize a hazard AND the authority to correct it. The authority can only be given by you, the employer, but it is also up to you to determine if that employee has the knowledge. How?
First, review what training, education, and experience they have in the given topic. Then speak to them about their knowledge and take time to view it in practice. If you feel they meet the definition, then they can be your Competent Person, but your responsibility doesn’t stop there. You must periodically check on them. See that the work that they are doing is worthy of a Competent Person. Make sure that nothing they are saying or doing renders your original determination obsolete. If it does, speak with them about it and retrain them. Nothing says that once you remove the Competent Person status from somebody that they can never earn it back, but it is also true that once somebody has been deemed a Competent Person, it doesn’t mean that it can’t be taken away. Your Competent Person must continue to demonstrate their abilities or have the designation removed.
Program maintenance really relies on various inspections: inspections of work that’s being done, inspections of procedures in practice, inspections of your workers’ knowledge, inspection of your equipment, and more. Never assume that just because something is good once that it will always be. Make these inspections part of your overall program, assign them to qualified people, and make sure they get scheduled so that they aren’t forgotten. This will help keep your program both fresh and effective over time.