In prior articles we have discussed the importance of safety programs, how to implement them correctly, and how to “measure” them using leading and lagging indicators. Inspection of the workplace is always a critical part of a safety program but “auditing” your program is also important. By auditing, we mean how to score your efforts to evaluate the objectives and effectiveness of the program. After serving on the ANSI/ASSP A10 Committee for over 10 years, I believe the standards and information they publish can be very useful to construction companies of all sizes. Sheet metal fabrication shops could benefit from the standards as well since the topics crossover in many ways.
One standard the committee worked on is A10.39 – Construction Safety and Health Audit Program. According to the American Society of Safety Professionals (ASSP), this standard “establishes an internal method of measuring compliance with an organization’s written safety and health program requirements.” A free project audit guide is available from ASSP at https://www.assp.org. This guide is basically Appendix A and B of the standard and provides some helpful information.
The guide offers a scoring system, but each company should develop their own audit scoring in order to capture the actual program priorities and corporate culture. A yearly audit of the safety program is likely the best timing for most companies since the audit should be detailed to include records review of policies, procedures and specific written programs; thorough workplace / jobsite evaluations, and interviews with key personnel and staff.
The main sections of the audit guide are:
- Administration
- Standards / Regulations
- Inspection / Abatement
- Safety Committees (if applicable)
- Allegation of Reprisal
- Training
- Recordkeeping and Reporting Requirements
- Participation
These topics are important to evaluate and address as part of a company safety culture. Administration covers the basics of a safety program including the goals and objectives of the program, applicable written policies and procedures, personnel rights and responsibilities, personal protective equipment (PPE) and other “necessities.” Human resource / safety related topics to audit include staffing and job descriptions, communication, and discipline.
Standards and Regulations should be the compliance guidance that each firm needs to follow. We have discussed how “compliance” can be difficult but prioritizing and focusing on the standards and codes that have the most impact on your project success provides a good place to start.
As mentioned, Inspection and Abatement includes a walkthrough of your shops and jobsites looking for safety and health hazards and then abating (correcting) them to avoid accidents and regulatory citations. Feedback from employees during these inspections can provide insight that may not be obvious to the “inspector.” Companies should be willing and able to spend the time and money to make the proper workplace revisions.
Safety Committees can be an asset to a safety program, but company owners and management should proceed with vigilance. Worker input is important and a process for providing feedback should be in place. Safety committees and workers often make recommendations that will cost money to fix, and management needs to be ready to “face the music” when these topics are discussed.
Employees have the right to report an unsafe or unhealthful working condition so a section on Allegation of Reprisal will consider the policies in place to avoid discrimination or interference in the employee reporting process. OSHA has been very active in advocating for employee rights including “whistleblower complaints”.
Training is likely one of the most important aspects of a safety program, as we have discussed in several prior articles. Auditing training includes evaluating the training of all levels of management and specialists assigned to the various tasks and processes needed as well as coordination with employee representatives. Supervisors should be involved in all training programs since they are often the ones on the jobsite or shop floor with the authority and responsibility to guide workers in their everyday activities.
Recordkeeping and Reporting Requirements includes documentation of the training we just discussed. OSHA recording injuries and illnesses has changed over recent years so auditing these records should include ensuring they meet current requirements for availability to workers and retention. Also remember that “reporting” is different from “recording” and includes timely communication of applicable injuries and illnesses to OSHA and other authorities.
Safety and Health Participation simply addresses the outreach and resources available through the various programs. Sheet metal and HVAC companies can benefit greatly from marketing and advertising safety program success, related safety awards, and audit findings as more and more clients and general contractors are looking to work with companies that cherish and pursue safety excellence.
In summary, a safety and health program is essential for moving to a culture of safety excellence and regular audits of the entire program are critical in evaluating the success and failures. Learning from mistakes is often more significant than learning from success since the consequences are so apparent.
