Electrical contractors know they comply with all Occupational Safety and Health Administration (OSHA) regulations. However, compliance goes beyond the written standards. The OSHA Act specifically requires employers to provide a place of employment that is free from recognized hazards that are causing or are likely to cause death or serious physical harm. To accomplish this, contractors need a system to determine which hazards are present and methods to control or remove them. This article will present OSHA’s program on achieving full compliance followed by a strategy for implementing the program.

In January 1989, OSHA issued the Safety and Health Management Guidelines for general industry. The guidelines were called the Four-Point Program and simplified the directions on how to become compliant. These guidelines were based on the actions of companies that were extremely successful in reducing accidents. Although the program was established for general industry, the basic concepts can be applied to construction operations as well.

Management commitment and employee involvement

The company owner’s or manager’s attitude about job safety and health is critical. If management doesn’t view injury and illness prevention as a priority, neither will the employees. In order to have everyone on the same page, “safety first” must be a concern from the top of the organizational ladder to the bottom. The company policy must be clearly set and demonstrated through the management’s actions.

OSHA also has identified employee participation as a critical component of the program. Employees should play an active role in everything from establishing objectives for the safety program to identifying hazards in the field. A company safety committee that includes both management and employee representatives is recommended.

Work site analysis

It is an employer’s responsibility to know what could hurt employees. A work site analysis is a procedure that helps make sure hazards are identified. Two simple methods for completing an analysis are job site inspections and a review of company and industry accident records. Inspections can be performed using a checklist provided by industry experts or by simply trying to focus on injury agents. Injury agents are things such as sources of energy (electrical, radiation, gravitational, etc.) and dangerous actions or items (such as the use of sharp tools). The accident records review should include overall statistics and individual investigations. The statistics reveal which hazards are commonly encountered. This helps to set priorities. Individual accident investigations will provide the details on the hazards faced by employees. When combined with an inspection of the job site, past, present and future hazards are more readily identified.

Hazard prevention and control

Once the hazards are known, controls can be established. The three methods of control are engineering, administrative and personal protection. Substituting a less toxic material for a toxic substance or placing guardrails on a scaffold are engineering controls. OSHA requires that engineering controls be used first in an attempt to eliminate the hazard. Engineering controls provide protection from the hazard with little or no action required on the part of the employee. For example, guards placed on tools and equipment prevent workers from accessing hazardous nip-points. Workers need only ensure that guards are in place and operational.

Administrative controls are the second line of defense. These controls include polices, procedures and training. Using a procedure that schedules employees to work for short durations to keep exposure under a time-weighted limit would be considered an administrative control. Training employees to wash hands to eliminate exposure to hazardous substances is another example.

Wearing a body harness or a respirator is personal protection. Personal protective equipment (PPE) should be used only as a last resort when engineering and administrative controls fail. PPE use offers several limitations. It depends on the employee’s willingness and ability to wear the equipment properly. The application of PPE must always be supplemented with administrative controls. Using any type of PPE requires training.

Training for employees, supervisors and managers

OSHA could not emphasize this point enough. Thorough training for everyone involved is the best way to ensure a safety plan’s success. Special attention should be given to new and newly assigned workers. They are at the greatest risk of injury if they are not properly prepared. It is important that supervisors know all the hazards found in the workplace and how they can effec-tively be controlled. Both employees and supervisors should receive ongoing safety training. It keeps them up-to-date, and it keeps safety at the front of their minds on a regular basis. All employees, managers, staff, supervisors and workers should understand the role they play in the company safety program.

Compliance strategy

The Four-Point Program helps employers identify hazards and controls. It also provides an outline of what an effective safety program should contain. Unfortunately, the development and implementation of a working plan is left to the individual employer, who must find the time and gain the expertise needed. Large companies that hire safety directors often find these individuals burdened with administrative tasks, such as recordkeeping, reporting and documentation.

Small contractors with no professional staff also struggle with changing regulations, interpretations and enforcement policies.

A system is needed to help identify and assign required tasks. The system should be based on sound principles and take advantage of the existing tools and available resources. An effective system for managing everything from small incidents to major catastrophes is the National Incident Management System (NIMS). Taking basic direction from NIMS and using resources such as the National Electrical Contractors Association (NECA) Safety Expert System Software, large and small employers alike can deploy the resources needed to implement an efficient and effective safety program.

In this modified version of the NIMS, the employer would act in the command role and must provide the required resources that include time, money and authority. As commander, the employer sets policy, assigns responsibilities and provides over-sight of the program. This also would fulfill OSHA’s directive that management demonstrate commitment.

To meet other program requirements, the employer should designate planning, operations, logistics and finance entities. Planning personnel would prepare and file all documents needed for the safety program. Operations personnel would carry out the actions required by the program. Logistics personnel would ensure support and resources were available on the job when needed. Finally, finance would make sure funds were available for the program and track costs.

Using this approach, the company can put into play a collective effort. Even small companies can quickly develop and implement an effective safety program. The team would report to management or the commander through a planning chief with the program or safety plan. The planning chief can be a safety director, supervisor or competent clerical worker. However, using a clerical person for planning frees the safety director or supervisor to serve in a different role. If the planning chief is a clerical person and the company has a safety director, you may want to change the reporting role. The planning chief could prepare the written report or safety program documents for the safety director who, in turn, would report to management.

The job of the planning chief is to ensure that the plan documents the team’s efforts. They monitor assigned tasks and pro-vide reports to management. Tools like the NECA Safety Expert System can help both professionals and novices complete these tasks. The NECA Safety Expert System contains model programs, checklists, audits, policies, procedures and a library of training materials. It also provides the recordkeeping required by OSHA. The OSHA 300 Log, 300A, 301 and training records all can be generated using this program. Using tools like the NECA Safety Expert System saves time and improves productivity, especially the productivity of full-time safety professionals.

The objectives of the program and resources needed are identified by an operations chief, logistics chief and their teams. Operations might include supervisors and/or safety director. A logistics chief might be the project manager. Team members would meet to identify the safety hazards present, written programs or procedures, and safety equipment needed and when. This would be forwarded to the planning chief, who would prepare the plan based on the objectives and needs identified. Given an application like the NECA Safety Exert System Software, a clerical person acting as a planning chief could easily assemble the plan from the needs identified. In the absence of the NECA application, a safety director may need to take on this role and develop applicable programs and safety talks.

Completion of assigned tasks would then be performed by operations. This would be the supervisors and workers. For exam-ple, safety talks, audits, inspections and hazardous chemical lists can be assigned to supervisors in the field. They can enlist the help of workers and complete these tasks at the most opportune times. Logistics or the project managers will help ensure the resources are available as needed.

Of course, costs for completion of tasks and the resources needed are key parts of the plan. To ensure financing is avail-able for safety, estimating would need to serve as a finance chief. Estimators should include costs associated with safety and compliance are in all bids. They also should track costs and assist in purchasing process.

The brief and adapted version of the NIMS described here offers a limited application of the system and only one variation of how it may be applied. Employers are encouraged to look into the system to manage their safety program and any emergencies or events that may occur. NIMS enables users to expand or contract their operation to fit the task at hand. For more information, check out the Federal Emergency Management Administration (FEMA) Web site at www.fema.gov.

Ensuring OSHA compliance and the safety of all employees need not be an impossible task. OSHA has simplified compliance to four points:

1. Management commitment and employee involvement

2. Hazard analysis

3. Hazard control

4. Training

NIMS offers a structure for tackling tasks that must be done. If contractors put any or all of these into place, their safety program will be more efficient and effective. EC

O’CONNOR is with Intec, a safety consulting, training and publishing firm that offers on-site assistance and produces manuals, training videos and software for contractors. Based in Waverly, Pa., he can be reached at 607.624.7159 or joconnor@intecweb.com.