Having a Plan (And Using It) Is Crucial to Employee Safety
You should have a narrowly tailored Employee Health and Safety Plan for your business. You should also have an understanding as to how to use the plan on an ongoing basis. These two items are crucial to maintaining employee safety. Training your employees and subcontractors how to work safely and meet the safety requirements of your Employee Health and Safety Plan - a plan that should include proper documentation of that training - should take high priority.
What OSHA Expects From You: A Multi-level Approach to Safety
OSHA expects your employees and subcontractors to be properly trained, in how to approach their specific job duties, and in line with your Employee Health and Safety Plan. Among the best ways to address this training and instruction is to break it down into a multi-level approach, as below:
- Training at the time of hiring/contracting
- Training for job-specific duties that the employee/subcontractor will face in working for your business
- On-going training to continually educate and reinforce safe work practices for employees/subcontractors
Begin at the Time of Hire
Typically, the best time to start the process is at the time of hire. This is a prime opportunity to cover and reinforce a number of general safety topics (PPE, proper lifting procedure, OSHA Focus Four, etc.). Following the initial hiring/contracting phase, an employer can begin introducing job-specific safety training, including:
- The use of specialized equipment
- Fall restraint systems
- Hazard communication and reporting
- Job-hazard-analysis reports and assessment
Specific training may differ from employee to employee or subcontractor to subcontractor, and will likely need to be built upon when employees and subcontractors assume more advanced roles within the business.
Best Practice: Periodic Safety Training
Beyond the time of hire, employee training itself must be reviewed regularly-just as your Employee Health and Safety Plan should be reviewed and updated regularly-to meet and address changing work demands and safety needs.
Best Practice: Maintaining Documentation in the Event of an OSHA Investigation
Adequate records are important. If you find yourself facing an OSHA investigation, the proper documentation can be enormously helpful.
- Attendance sheets (to reflect actual attendance and participation on the part of your employees/subcontractors in periodic safety trainings)
- Informational hand-outs and one-sheets (to show that you were proactive in terms of offering your employees/subcontractors relevant safety information)
Proper documentation serves multiple purposes, such as indicating the continued and effective training of your employees/subcontractors, with the secondary goal of assisting your business in developing an effective defense to an OSHA citation should your business come under investigation.
Why You Should Speak to an Attorney about Employee Training and Document Retention
Employee training and proper documentation of that training are not separate pieces of your overall safety plan; rather, they can potentially serve as integral pieces of your overall Employee Health and Safety Plan - and as an integral part of the health and long-term success of your business as a whole.
