Recently OSHA Compliance Officers in two different Area Offices specifically requested digital copies of employers’ “Safety Program” instead of written copies. The employers understandably wondered why the Compliance Officers expressly wanted digital copies. An obvious concern was that the Compliance Officers wanted to expand the scope and to more easily be able to review the entire safety program, perhaps in anticipation of the eventual implementation of I2P2.
Various Area Offices advised that they were unaware of any push by OSHA to obtain digital copies of safety programs either to protect the environment or in order to “troll” through the safety programs. Providing digital copies of safety programs to OSHA is probably not a good idea. First and most importantly OSHA Area Offices have limited facilities, and you really do not want to irritate a Compliance Office by requiring him to print 100 pages on a slow printer. Moreover, for various legal reasons, many of which have nothing to do with OSHA, employers generally should utilize PDF copies.
· What if my “safety program” isn’t in one place? It’s integrated into various processes.
The inquiry raised other important questions. Some employers are increasingly incorporating their “safety procedures” into all aspects of their operations and processes, from bidding to purchase to production. If one does not know that, an observer might be surprised or concerned about certain policies not being in the designated “safety policy.” As employers integrate safety into all of their policies and procedures, they need to also ensure that they can explain to OSHA or interested customers where “safety policies” exist in writing.
· What about I2P2?
While I doubt that these requests had anything to do with preparation for I2P2, we do know that the current administration is serious about implementing I2P2, and is increasingly looking at an employers’ entire safety processes as part of the SVEP process or where no vertical OSHA standard clearly fits a situation. Some employers maintain broad corporate safety policies, but do not prepare job site or machine-specific procedures. Some safety programs neglect contractors and temporary employees. Some safety programs bear almost no resemblance with life on the work floor.
We will talk more about these subjects in the future, and I would appreciate any observations or observations about effective safety programs and integrating safety into all processes.