How to Get an OSHA-Required Safety Program Started (on a Shoestring Budget)

Transcription

1 How to Get an OSHA-Required Safety Program Started (on a Shoestring Budget) Jeff Schell Twist, Inc. Safety & Training Director jschell@twistinc.com (937) ext. 403

2 My Background From 1989 to 1996 Vulcan Tool and Omega Tool Companies General Production Employee Basic Prototype Assembly and Testing From 1996 to 2006 Contractor for Automotive Mfg. Co. Prototype Assembly Technician Engineering Test Technician December 2006 Notified of RIF

3 My Background From 2007 to 2008 Bachelors and Masters in Education Petitioned for retraining assistance under Fair Trade Act Approved and used funds to complete Masters degree From 2009 to 2017 Mound Street Academies English Career Skills Basic Safety Skills Employer Partnership From March 2017 Present Twist Inc. Safety and Training Director Now What?

4 Where Do I Even Start? 1. Know what safety programs are required for your type of business 2. Set priorities for establishing programs 3. Get your lead instructor / instructional designer trained 4. Use resources from the instructor s training to help you write your formal program 5. Line up audio / visual support for presentations and trainings 6. Enlist employee assistance to evaluate your training program

5 Is My Business Responsible for OSHA Reporting and Training Requirements? What type of business do you own or operate? Certain employers are expressly not covered by OSHA. This means none of the rules apply to these businesses. That includes: Churches and religious activities and businesses Self-employed people Farms that employ only immediate family members People who employ others for domestic services such as cleaning and child care.

6 Is My Business Responsible for OSHA Reporting and Training Requirements? How many employees do you have on the payroll? Businesses with 10 employees or fewer are exempt from: Occupational Safety and Health Act s injury and incident reporting (OSHA 300) Programmed inspections by Occupational Safety and Health Administration employees.

7 What if I am Unsure about Whether My Business Meets These Criteria? A business that is growing and evolving rapidly may be hard to fit into one of the exemption criteria Your business may change the type of work that it does, or add a new line of work. Your business activity may not entirely be described by an exempt category Thus, your business may be responsible for OSHA reporting and Training Requirements If you are unsure about whether your business needs to comply with OSHA reporting and training requirements, seek legal counsel! Fines for non-compliance could easily shut down a small, growing business.

8 OSHA Regulations and Standards by Industry Construction 29 CFR 1926 General Industry 29 CFR 1910 Agriculture 29 CFR 1928 Maritime 29 CFR 1915, 29 CFR 1917, 29 CFR 1918

9 Setting Priorities What are some good questions to ask when deciding on what program to begin? Where are most of our accidents occurring? OSHA 300(A) What kinds of accidents are happening? OSHA 300(A) What type of training could reduce accidents the most? OSHA 300(A) How about starting with the programs that OSHA cites most often?

10 Top 5 Most Cited General Industry Elements 1. Hazard Communication ,665 Violations 2. Respiratory Protection ,573 Violations 3. Lockout / Tagout ,406 Violations 4. Powered Industrial Trucks ,855 Violations 5. Machine Guarding ,448 Violations These programs are probably a good place to get started!

11 Now That We Know What Material We Need to Teach, Who should Teach It? A Qualified Person Sounds pretty straightforward, right? OSHA has definitions for competent people and qualified people They are not the same!

12 What makes a person Qualified? OSHA defines a Qualified Person in general industry (1910) as: One with a recognized degree or professional certificate and extensive knowledge and experience in the subject field who is capable of design, analysis, evaluation, and specifications in the subject work, project, or product.

13 What makes a person Qualified? OSHA defines a Qualified Person in construction (1926) as: by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training and experience, has successfully demonstrated his ability to solve or resolve problems relating to the subject matter, the work, or the project.

14 So if a Person is Qualified, Are They Ready to Teach Your Employees? Perhaps Is your trainer well-versed or educated in the specific subject matter they are responsible for teaching? Do they have extensive knowledge of the OSHA standards and requirements? Can they be certain that your company would pass an OSHA inspection of the subject matter written program?

15 The Trainer is Familiar With the Subject, So Some knowledge of the subject matter does not necessarily mean that they are ready to teach it In order to effectively conduct training programs, trainers must have a greater degree of understanding. How can an instructor explain complex or difficult concepts and answer questions without deep understanding and specific knowledge?

16 Where Can Our Trainer Learn the Material?

17 BWC Offers Education and Training in a variety of courses addressing: Industrial safety Construction safety Industrial hygiene Ergonomics Safety management Risk management.

18 Requirements for Enrollment in BWC Training Classes An active Ohio Worker s Compensation Policy Number Each policy number can enroll up to four attendees The best part about BWC training classes is the cost They are free! Classes are a service funded with the premiums you are already paying!

19 What Will I Learn from Attending BWC Training Courses? Comprehensive coverage of the OSHA standard Real-world applications for the material covered Printed materials useful for referencing the subject matter The name and contact information for an expert in the subject Most instructors are willing to answer questions and follow up with attendees, when requested Many times, and upon request, you will be provided samples or templates of written training programs Extremely useful as a guide in developing your own written programs

20 What if I m on a Budget and Need Training Materials? The Bureau of Worker s Compensation also operates a library where you can borrow: Training Videos Instructor s Guides Assessments These materials are all available for all current BWC policy holders to borrow, free of charge! The only cost is the return postage you pay to return the title to the library!

21 Have Employees Evaluate Your Training s Effectiveness Assess your employees before and after the training session Demonstrates student growth from start to finish Have employees who attend training evaluate the session: Materials Instructor Activity Don t take criticism personally use the results to improve your program!

22 Where Can I Find The Bureau of Worker s Compensation Catalog? Call and request a printed copy See a BWC representative who may be in this room

23 Now That You Have Begun Once your company has made the commitment, and begun an employee training program, you are ready to improve You may want to consider partnering with the BWC and OSHA or participating in the SHARP program. Our own experience has been very positive, and they have helped us improve our safety culture over the years.

24 Elements of an Excellent Safety Culture Every Incident can be avoided. No Job is worth getting hurt for. Every job will be done safely. Incidents can be managed. Safety is Everyone s Responsibility. Safety/Best manufacturing practices Safety standards, procedures and practices must be developed. Training- Everyone must understand AND meet the requirements. Working Safely is a Condition of Employment

25 Questions and Answers Thank You for Your Attention Have a Happy and Safe Holiday Season!