To help comply with regulations from the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) and maintain a safety plan, some larger organizations have a safety professional on staff to conduct inventory and safety audits, as well as compile material. In smaller organizations, this responsibility falls to you, the facility manager. Either way, educate yourself on OSHA regulations. This knowledge will be invaluable in identifying hazards and developing a comprehensive training plan for compliance.

For instance, whenever changes occur to the safe handling of chemicals, review your training curriculum. It is easy to buy a newer, better chemical from a different manufacturer and have personnel start using the chemical without appropriate training or safety data sheets (SDS) on hand. You are not compliant with OSHA regulations if you conduct business in this fashion.

In addition to chemicals, there are less obvious hazards within departments that managers must be aware of. These, too, will require regular training. Some to consider: Ladders, any wet cleaning operations around electricity, mixing chemicals, bringing cleaning chemicals or compounds from home, changing lamps from a ladder or aerial platforms, vacuuming stairwells, personal protective equipment applications, placing vacuum cords across doorways, and slip, trips and falls.  Another common hazard that often gets overlooked is the exposure to bodily fluids, which is covered under Bloodborne Pathogens.

Training on the Bloodborne Pathogens Standard must be top-of-mind, as it can have lethal consequences. This standard is outlined in its entirety on the OSHA website and managers are encouraged to review it completely. The standard is lengthy, detailed and can be difficult to understand, but it is important managers take the time to do so.

Pay particular attention as to the regulations and training requirements under the Bloodborne Pathogens Standard, keeping in mind that we are in General Industry 29CFR1910.

It is also important to familiarize yourself with the definitions OSHA uses in this standard: OPIM’s (Other Potentially Infectious Materials); Work Practice Controls; Exposure Control Plan and Determination of Exposures; Universal Precautions (Methods of Compliance); Personal Protective Equipment (PPE); Housekeeping Practices; Laboratories (special situation); Required Training; Hepatitis A Vaccination and Declination, Needle Stick Log and procedures of handling needles, and so on.

Read, study, understand and implement this standard. As a manager, it is your job to advocate for a safe work environment.

OSHA Regulations That Protect The Department

Even when proper training on OSHA regulations is in place, accidents can happen. If they do, take action. Begin by reviewing the accident investigation report. Analyze what happened and what could have been done to prevent the accident. Document this information and then adjust your training material to reflect how to avoid the accident moving forward.

Managers are also encouraged to create a list of any previous accidents and near misses, in order of occurrences and frequency. Apply the information to your Job Hazard Analysis, but also take a second look at your training. If exposures are considered critical and have a recurrence pattern, ramp up training in an effort to minimize future occurrences. You may even develop a safety bulletin or document of procedures to have for your training program and criteria.

But even with a proactive plan and extensive training in place, accidents can happen. This is why if you are involved in business today, you need to educate yourself on OSHA regulations. Yes, it may be confusing and it does take time to develop and study, but it is a cost of doing business, and it will protect you, your staff and your department in the long run.

For example, if you are in a situation that requires OSHA’s presence at your business or job site, it will be imperative to have your training material available and the employee’s signature acknowledging that they were trained in safe practices — proof of training that is irrefutable must be acknowledged in writing.

This paperwork indicates that the employee not only received training on OSHA regulations, but they understood it (managers must conduct training in a language the employee understands, not just English).

Well-documented training will illustrate the efforts managers make to keep employees safe. Without your written documentation, from OSHA’s perspective, training did not occur and the resulting fines will reflect your negligence.

As a manager, you must develop a mindset that encourages safe work practices and makes safety a priority within the department. Create an atmosphere of trust and value with the employees. Let everyone know just how important safety is at your company. If ignored, expect a knock on your door and large fines to follow.   

Additional Information On OSHA Regulations

For a primary safety reference guide, review the Occupational Safety and Health Administration code — formally known of as 29CFR1910 (General Industry) — at www.osha.gov.

Managers are also advised to sign up for the free “OSHA Quick Takes” newsletter, which provides current changes and updates to relevant laws.

John M. Poole, Jr. is an authorized OSHA Outreach Training consultant and holds the following designations: Master Registered Executive Housekeeper, Registered Building Service Manager, ISSA Certification Expert, and Assessor for the Cleaning Industry Management Standard.

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POSTED ON: 2/21/2013