Behavior Safety Associates designs and implements safety and health (or IIP) programs to include a system for two-way communications with employees. BSA’s experts develop a readily understandable communications plan to proactively communicate occupational safety and health information to all affected employees. The communications plan identifies and establishes provisions designed to encourage employees to inform the employer of near-misses and hazards at the worksite without fear of reprisal.
While employers are not required to establish vertically-integrated Safety Leadership Team, it is an option to consider. The SLT becomes the driving force behind the safety culture. The members are “the eyes, ears and feet” of the safety culture. By having members from management as well as line or hourly employees on the SLT, safety issues get resolved faster; red tape and bureaucracy can be eliminated. If the organization chooses to do so, employers who elect to use a Safety Leadership Team (SLT) to comply with the communication requirements are presumed to be in substantial compliance if the SLT:
- Meets regularly but not less than quarterly.
- Prepares and makes available to affected employees written records of the safety and health issues discussed at the committee meetings.
- Review results of the periodic scheduled worksite inspections.
- Reviews investigations of occupational accidents and causes of incidents resulting in occupational injury, occupational illness or exposure to hazardous substances, and where appropriate, submits suggestions to management for the prevention of future incidents.
- Reviews investigations of alleged hazardous conditions brought to the attention of any committee member. When determined necessary by the committee, it may conduct its own inspection and investigation to assist in remedial solutions.
- Submits recommendations to assist in the evaluation of employee safety suggestions.
- Upon request of OSHA, verifies abatement action taken by the employer to abate citations issued by OSHA.
If employees are not represented by an agreement with an organized labor union, and part of the employee population is unionized, the establishment of labor-management committees may be more complicated. If the organization elects not to form a labor-management SLT, be prepared to formalize and document the required system for communicating with employees. Here are some helpful tips on complying with this difficult section:
- The communication system must be in a form “readily understandable by all affected employees.” This means the organization should be prepared to communicate with employees in a language they can understand, and if an employee cannot read in any language, it must communicate with them orally in a language “readily understandable.” The communication system must be “designed to encourage employees to inform the employer of near-misses and hazards at the workplace without fear of reprisal.” It must be a two-way system of communication.
- Schedule general employee meetings at which safety is freely and openly discussed by those present. Such, meetings should be regular, scheduled, and announced to all employees so that maximum employee attendance can be achieved. Remember to do this for all shifts. Many employers find it cost effective to hold such meetings at shift change time, with a brief overlap of schedules to accomplish the meetings. If properly planned, effective safety meetings can be held in a 15 to 20 minute time frame. Concentrate on:
- Occupational accident and injury history at your own worksite, with possible comparisons to other locations in your company.
- Feedback from the employee group.
- Guest speakers from your worker’s compensation insurance carrier or other agencies concerned with safety.
- Brief audio-visual materials that relate to your industry.
- Control of the meetings.
- Stress that the purpose of the meeting is safety. Members of management should attend this meeting.
- Training programs are excellent vehicles for communicating with employees.
- Posters and bulletins can be very effective ways of communicating with employees. Useful materials can be obtained from Behavior Safety Associates, OSHA, the workers’ compensation insurance carrier, the National Safety Council or other commercial and public service agencies.
- Newsletters or similar publications devoted to safety are also very effective communication devices. If the organization cannot devote resources to an entire publication, make safety a featured item in every issue of the organization’s newsletter.
- A safety suggestion box can be used by employees, anonymously if desired, to communicate their concerns to management.
- Publish a brief company safety policy or statement informing all employees safety is a priority issue with management. Urge employees to actively participate in the program for the common good of all concerned.
- Communicate concerns about safety to all levels of management.
- Document all communication efforts, as the organization may be required to demonstrate to OSHA a system of effective communication is in place.