Safety professionals have long been advised to integrate safety into overall business operations rather than to make it a stand-alone function. According to the European Agency for Safety and Health at Work, “…sound OSH management, integrated into an organization’s overall management and business, is one of the main success factors to ensure improvements in workers’ health and safety.”

What is the most direct path to that much-desired integration? One approach developed by the Ohio Bureau of Workers’ Compensation (BWC) takes a business plan approach.  The strategy, 10-Step Business Plan for Safety, A Guide for Developing Organizational Excellence in Safety and Health Management,is the subject of this Compliance Report. While some of the steps are familiar and expected, others go beyond the common wisdom when it comes to safety and health management systems.

Step 1: Active senior management

The first step in the BWC business plan model involves leadership. According to BWC, “visible senior management leadership within your organization promotes safety management as an organizational value.”

Members of senior management, including the top on-site executive, should act as role models for how all employees contribute to a safe working environment. Examples of active leadership include:

• Authorizing needed resources for accident prevention;
• Discussing safety processes and improvements regularly during staff or employee meetings;
• Holding management accountable for accident-prevention activities and for managing prevention processes;
• Annually assessing the success of the safety system through surveys, personal interviews, behavior sampling, and other means; and
• Encouraging employees to take an active part in maintaining a safe workplace.

Under the BWC plan, senior management takes the lead on safety and health. The visible, active support and commitment of those at the top encourage employees to do their part. Recommended leader actions can include:

• Issuing a written safety policy as a core organizational value and assigning employee roles and responsibilities;
• Establishing annual and long-term safety goals;
• Including safety as an agenda item in all meetings;
• Regularly reviewing progress of OSH processes with supervisors and employees;
• Participating in departmental safety surveys;
• Addressing all accident-investigation reports and near misses;
• Presenting safety recognition awards to deserving employees;
• Talking with employees about working safely during walkabouts; and
• Participating in safety training as a student.

Step 2: Employee involvement and recognition

An effective program requires that employees be involved in and recognized for their participation in the safety process. Examples of participation opportunities include:

• Participating in accident investigations;
• Conducting safety and health audits;
• Serving as safety trainers; and
• Serving on focus groups, committees, and safety and health involvement teams, which help focus dialogue between management and nonmanagement employees.

Teams handle problem solving and decision making for safety and health issues and include management and line employees in roughly equal numbers. They can be cross-functional or made up of natural work groups and should meet regularly but not less than quarterly with a rotating facilitator. Empower teams with responsibility for developing and implementing effective safety solutions.

Recognize employees for:

• Behaviors that contribute to accident prevention,
• Contributions to worker protection—from volunteering to make a presentation at a safety meeting to serving as a safety mentor for a new employee,
• Participating in perception surveys, and
• Suggesting and following through on safety and health improvements or completing special OSH projects.

When it comes to influencing employee behavior, the BWC believes there is a place for both positive behavior reinforcement (praise and other recognition) and negative reinforcement (discipline for unsafe behaviors and decisions). But dwelling too much on the negative leads to faultfinding and blaming employees, which causes employees to see safety in a negative light.

One approach is to ask supervisors to positively recognize at least one employee each day for safety-promoting behaviors and activities. “Recognition costs nothing but is a visible reminder of the importance the supervisor and the organization place on integrating safety into the culture of the organization and into day-to-day operations.”

Step 3: Medical treatment and return-to-work practices

Quality medical care provided in a timely manner helps injured employees and contains workers’ compensation costs. Successful employers work hard to establish and maintain relationships with healthcare providers.

Establish lines of communication with area clinics, hospitals, and providers. Educate them about the nature of your business, your workforce, risks, and controls. Make sure to clarify roles, responsibilities, and expectations.

Establish postinjury or disability management policies and procedures that emphasize the following elements:

• Informing employees about how to get medical treatment;
• Encouraging immediate reporting of injuries and illnesses;
• Regularly communicating with injured or ill employees who are off work.
• Investigating all incidents within 24 hours;
• Providing a modified duty or transitional work program that brings employees back to productivity as they recuperate; and
• Working closely with the healthcare provider, rehab specialist, and claims administrator to identify the best solution for each affected worker.

Step 4: Communication

Regular safety and health communication keeps employees informed and, done right, elicits feedback and suggestions. Safety communication is a two-way process—from top down and from bottom up. Leaders should consistently share safety messages. And employees should be encouraged to identify and report obstacles to safety without fear of reprisal.

Consider communication strategies like these:

• Scheduled one-on-one talks between the supervisor or foreman and each employee to discuss safety concerns, suggestions, etc.;
• A physical or digital safety bulletin board to post policies, notices, and precautions, and to help keep safety top of mind;
• Memos that summarize discussions and plans and provide information on company safety performance goals and results;
• Formal or informal group safety meetings that give leaders and employees an opportunity to discuss safety and seek input;
• Regular in-house newsletters, safety e-mails, electronic reminders, paycheck stuffers, and other written communications; 
• Safety signs posted in key locations throughout the facility to remind employees of safe work practices, dangerous conditions, and their role.

Step 5: Timely notification of claims

When an injury occurs, the most critical step is to arrange for appropriate medical care for the employee. Next, investigate and document the circumstances, and report the injury to the claim handler.

Among other benefits, quick reporting of claims:

• Shows care and concern for the injured employee,
• Prevents delays and/or confusion in the claims process,
• Reduces the potential for fraud or abuse, and
• Reduces the potential for litigation.

Timely reporting helps open lines of communication with providers and insurers, develops accurate information to help manage the claim, and gets benefits to the injured employee on a timely basis.

Step 6: Assign an accident-prevention coordinator

The accident-prevention coordinator supports line management, supervisors, employees, and safety staff in the effort to achieve effective safety systems and processes. Roles for the coordinator can include:

• Identifying safety-training needs through surveys, interviews, and other methods;
• Helping supervisors make needed safety changes and improvements;
• Identifying and communicating new safety and health requirements;
• Compiling and sharing injury and illness data;
• Tracking progress on safety and health projects and concerns; and
• Working with employees to optimize safe work practices.

According to the BWC, the coordinator acts as a kind of in-house consultant, providing advice and support but leaving the activities of implementation to line managers and supervisors.

Step 7: Conduct orientation and training for all employees

Develop a written safety and health training plan with specific objectives and instruction procedures. The plan should include a safety and health policy statement, spell out employee responsibilities, and cover required OSHA training topics like recordkeeping, hazard communication, bloodborne pathogens (if applicable), and safe work practices.

Other training topics to be covered could include:

• Procedures for the safe and efficient use of machinery and tools;
• Ergonomic risk factors and injury prevention;
• Chemical hazards and prevention of contact or exposure; and
• Procedures for lockout/tagout, hot work permits, and confined space entry as needed.

According to the BWC, the goal of any training program is not just to impart knowledge, but also to change behaviors and improve decision making. The fact that nearly half of all injured workers have been on the job for less than a year underscores the critical importance of training for new employees. But don’t stop with new-hire training. Make sure to offer training in these circumstances:

• Regular refresher safety training to all employees.
• Thorough training for any employee with a transfer or new job assignment. These employees often lack adequate training because they’re viewed as temporarily filling in for regular employees.
• Retraining before or when you introduce new equipment, processes, procedures, or materials to ensure that your training remains responsive to the work environment.
• Retraining when you identify a new or previously unrecognized hazard, or as the result of an incident or near miss.

All training should reinforce the importance of prompt reporting of hazards or potential hazards. Training documentation is essential and should record the date, topics covered, instructor’s name, and employees participating.

Ask employees to reflect on what they’ve learned, for example, via a written quiz. This adds to the documentation, contributes to understanding and retention, and gives training more importance in employees’ eyes. Written responses can be a vehicle for constructive feedback from employees.

Step 8: Put safe work practices in writing

You know what you expect from employees, but publishing safe work practices clarifies your understanding, and theirs, relative to safe work practices, consequences, etc. Identify, document, and share general and job-specific safe practices with all employees. Ask them to sign a statement indicating that they have read and intend to comply with the rules and practices and understand what happens if they don’t.

Examples of generally expected practices:

• Follow good housekeeping rules and be accountable for finding and eliminating hazards.
• Wear, properly use, and care for personal protective equipment and respiratory protection.
• If trained, apply first-aid procedures as needed.
• Follow lockout/tagout procedures.
• Follow confined space entry procedures if applicable.
• Comply with hazard communication and chemical safety rules.

Task-specific safety practices should be posted in work areas. A good source of these is job hazard analyses, which break down a task into its components, identifying the risks and mitigations associated with each step.

Developing and collecting safe practices is an excellent opportunity for employee engagement. One approach is to create a safety involvement team to develop a handbook or app that reflects best practices for every job in your company. Include department-specific information as well as your safety policy. Add comments by your top leadership to set the tone and give the publication importance. Make sure the content is reviewed by employees who actually perform the tasks.

Relevant sections of the handbook or site can be used for training and should be reviewed with employees on a regular basis, at least annually. Ask employees to sign a statement that indicates they have read the handbook, are familiar with the contents, and agree to comply.

Step 9: Create a written safety and health policy

A written policy signed by your top leader expresses the organization’s values and commitment to workplace safety and health. It sets the tone for a meaningful program and can help ensure that safety is not a stand-alone activity, but it is integrated into the operation in the same way that quality, productivity, human resources, and other essential business goals are integrated.

The policy should be introduced during new hire orientation and reviewed with all employees at least annually. The document should describe the specific roles of managers, supervisors, team leaders, and employees relative to safety and health. And it should express the company’s commitment to bringing injured or ill workers back at the earliest opportunity.

Other recommended elements for a safety and health policy include:

• The organization’s philosophy of worker protection,
• Specific objectives of the safety program,
• Names of those accountable for program components,
• General responsibilities of all employees, and
• Statements about the company’s belief that safety should never be sacrificed for production or expediency.

A policy ensures that, at least on paper, everyone in the organization is operating from the same vantage point. It gives you a road map and provides a consistent point of view when incidents arise. A strong policy also helps you better defend claims regarding a possible breach of your obligations under the law.

Step 10: Sharpen recordkeeping and data analysis

Use audits, surveys, and records review to assess the success of your program and identify areas where improvement is needed. Good records are an essential element of a successful safety and health management system. They help you understand where, why, when, and to whom accidents occur. And they let you benchmark progress against other departments, divisions, or even competitors.

You can also use methods like employee perception surveys, suggestion programs, and one-on-one safety reviews to gain insight into how your processes are working.

Many businesses find value in sharing safety performance data, including lagging indicators like the number of unsafe behaviors observed. Some prefer to rely on leading indicators such as the number of:

• Safe behaviors recognized,
• Near misses reported,
• Safety suggestions made and implemented,
• Safety problems solved,
• Safety observations conducted, and
• Hazardous tasks performed without incident.