Safety and Health Management Systems

What is it, and Why is it Beneficial?

During the COVID-19 pandemic, many employers elected to close their workplaces to outside visitors or contractors except those that were necessary for the business to continue to function.  Third-party audits and other proactive safety activities ground to a halt and as the pandemic continued, many employers realized that their safety programs, policies, procedures, and culture had degraded during efforts to remain operational.  

What practices can help create a sustainable safety culture that is able to succeed even in circumstances such as a vacancy in the EHS department up to and including a global pandemic?  

The best practices to follow are discussed in OSHA’s Recommended Practices for Safety and Health Programs (SHMS, OSHA 3885) revised in October 2016. These practices help employers create a safety program and culture that is self-sustaining, and capable of maintaining effectiveness in the face of extreme upheaval. We at SCR Safety Solutions have had the opportunity to observe the success of such a program with a client that had not had any third-party evaluations in over three years. In their first assessment after a pandemic-induced hiatus, the SCR Safety Solutions team did not identify any of the usual areas of concern in a manufacturing environment.  Further, the recommendations that were provided to the client were primarily best-practices intended to further strengthen their existing program. So, what does this set of OSHA recommended practices consist of?

Some of the practices discussed in the SHMS document are operations that already exist in most employer sites.  This allows employers to refine those existing practices while incorporating the additional program elements described in OSHA 3885.

The two most essential elements of a SHMS program are management leadership and employee involvement. Without these two things in place and performing well, the rest of the program will be less effective. Management must make safety a core value and a condition of the production process, demonstrating a commitment to continuous improvement of the program. Employees must be involved in all aspects of the program, from setting goals to communicating concerns or opportunities to the management team. These components can be the most difficult part of the SHMS program to implement.

Often, the management team feels that they should be responsible for all aspects of the safety program and allow associates to focus exclusively on their respective job duties. While this can be an understandable position, employees spend more time at work than at home, often performing routine specific tasks and giving them responsibility for features of the safety program gives them a sense of ownership. Second, it promotes further involvement for hourly associates when the management team actively solicits information and acts upon recommendations that enhance site safety.

The remaining components of the SHMS program often are pre-existing and can be enhanced to be part of a complete Safety and Health Management System. These are as follows:

Hazard Identification and Assessment: Most employers have performed some type of hazard identification either internally or with the assistance of third parties such as insurance companies, consultants, or State programs. This process can be completed any number of ways, but as a best practice some third-party involvement is recommended to ensure that the site is being reviewed with a fresh set of eyes that can support the identification of any remaining potential hazards.

Hazard Prevention and Control: Once a potential hazard is identified, the next step is to either prevent or control it through a combination of engineered methods, administrative work practices, and/or PPE. Frequent and regular inspections of the work area will help ensure that hazard prevention and control remains effective. 

Education and Training: Training on OSHA required topics is typically well-established for most employers, but the training described in the SHMS program is an additional layer that provides hazard recognition training to associates, informs them how to report deficiencies, and methodologies that can be used to control hazards. Additional training may be necessary depending on the employee’s role in the SHMS program. Keep in mind, this does not have to be formal classroom training and can be peer-to-peer, on-the-job training, or include demonstrations.

Program Evaluation and Improvement: This is where the employer determines program effectiveness through leading and lagging indicators. Leading indicators include but are not limited to; level of worker participation, number of employee safety suggestions, number of hazards reported and corrected, number and frequency of site walkthroughs, etc. Lagging indicators include number and severity of injuries, worker’s compensation data including claim rates and cost, and exposure monitoring results that demonstrate overexposures in the workplace. Once the evaluation has been completed, a plan to address program opportunities should be developed.

Host Employers, Contractors, and Staffing Agencies: Any worksite can become a multi-employer worksite and mechanisms to convey information about potential site hazards, measures to control hazards, how to report an injury to the host employer, contractor, or temporary agency, how to alert the host employer, contractor, or temporary agency to a safety concern, and strategies for verifying compliance with the program are needed. Often, this component of the program is overlooked by employers who rarely use temporary labor, contractors, or other vendors, but preparation for the presence of outside entities is a best practice for all employers.

In summary, implementation of the Recommended Practices for Safety and Health Programs helps employers maintain a sustainable and effective program whose benefits ultimately include a reduction in accidents and incidents, costly downtime, and the potential for OSHA inspections. To learn more and download a copy of OSHA 3885, click the link below.

Safety Management – A safe workplace is sound business | Occupational Safety and Health Administration (osha.gov)

Tags: Health Management Systems, OSHA, Safety, SHMS