Perspectives On Safety In 2019: Are You Compliant?

Written by AJ Hale Jr. CSM-LSP, CompOne Administrators Safety & Loss Prevention Risk Manager

When we discuss OSHA and MIOSHA, what we are talking about are “Federal Laws” and “State Laws.” They are not suggestions, opinions, options or recommendations.

OSHA Standards
The OSHA standards are divided into four major categories based on the type of work being performed: Agriculture (29 Code of Federal Regulations (CFR) Part 1928), Construction (Part 1926), General Industry (Part 1910) and Maritime (Parts 1915, 1917 and 1918) employment.

State Standards, such as MIOSHA for Michigan, may adopt the federal standards “as is”, or they may add language that may make the standard even more restrictive. However, the state standards can never be more lenient than the federal statutes. In Michigan, we have:

  • General Industry Safety and Health Standards (94 Safety Standards &
    38 Health Standards)
  • Construction Safety and Health Standards (37 Safety Standards &
    28 Health Standards)
  • Administrative Standards for All Industries (7 Standards)
  • Agriculture Operations Standards
    (11 Standards)

Feeling Overwhelmed?
You are not alone. Every business is required to comply with the same regulations. Compliance requires a strategy, commitment and resources. Let’s take a moment to discuss the reason why these regulations exist in the first place.

The Human Toll
More than 4,500 workers are killed on the job every year, and approximately 3 million are injured, despite the fact that by law employers are responsible for providing a workplaces free of recognized hazards. If all employers simply corrected the top 10 hazards, the number of deaths, amputations and hospitalizations would decline dramatically.

The top 10 citations in 2018 were:

  1. Fall Protection – General Requirements
  2. Hazard Communication
  3. Scaffolding
  4. Respiratory Protection
  5. Lock Out / Tag Out
  6. Portable Ladders
  7. Powered Industrial Trucks
  8. Fall Protection – Training Requirements
  9. Machine Guarding
  10. Eye and Face ProtectionOne remarkable thing about the list is that it rarely changes. Year after year, OSHA inspectors see thousands of the same on-the-job hazards, any one of which could result in a fatality or severe injury.

How Accountable is Accountable?
The “Worker Endangerment Initiative,” a joint effort between the Department of Justice (DOJ) and Department of Labor (DOL) to utilize the enhanced penalties available under environmental and Title 18 felonies to prevent and deter crimes that put the lives and health of workers at risk.

Sally Quillian Yates, former US Deputy Attorney General, said, “Given the troubling statistics on workplace deaths and injuries, DOJ is redoubling its efforts to hold accountable those who unlawfully jeopardize workers’ health and safety.”

Value of Writing Procedures:
Policies and procedures are the strategic link between the company’s vision, and its day-to-day operations. So why is this important to you?

Well-written business policies and procedures allow employees to clearly understand their roles and responsibilities within predefined limits.

Developing clearly written policies and procedures that are documented, updated, and followed brings structure to an organization and assists in the day-to-day decision making processes.

Safety Based Value
Written policies and procedures are important tools for preventing loss and defending your organization in legal proceedings should they occur. Clear description of work duties and how to perform them will decrease and minimize the frequency and severity of incidents.

Involve Entire Workforce
Ideally, employees should be formally trained and upon completion of the class, sign an attendance sheet which acknowledge their understanding of your organization’s policies and procedures.

Major benefits gained

  • Employees are provided with information that allows them freedom to carry out their job and make decisions within defined boundaries.
  • Employees understand the constraints of their job without using a ‘trial and error’ approach, as key points are visible in well-written policies & procedures.
  • Everyone is working off the same page. Employees are provided the “official” guidance on how they should go about their tasks safely and efficiently.

Policies and procedures enable the workforce to clearly understand individual and team responsibilities, thus saving time and resources.

  • Clearly written policies and procedures provide legal protection.
  • They send a “We Care!” message, “The Company wants us to be successful at our jobs”.
    A safe work environment produces happier workforce, at all levels.

Honest Internal Assessment: So Where Does Your Company Stand?

  • Have you completed a Management Procedure / Policy Audit?
  • Have you completed a Site Safety Audit?
  • Is there sincere executive level support?

Questions To Ask Yourself

  • Are your Policies and Procedures current with today’s Standards and Regulatory requirements?
  • Can you demonstrate through documentation, that an annual review of these policies and procedures has been completed?

Should you require assistance with understanding or applying the OSHA or MIOSHA Standards, please contact AJ Hale, CompOne Administrators Inc./Rizikon, at 269-789-9166 or

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