If it isn’t written down, it didn’t happen –part 2 (Written Programs)

Are you a safe company?  Do you teach your employees what to do in the event of an emergency or how to act properly in a work environment (like in, sexual harassment)?  According to the government, if you didn’t write it down, it didn’t happen.

Regardless of the number of employees you have, there are some programs that are required be written down with employees having access to them.  People have short memories and if you DO have a legal claim against you, how will you ever be able to prove that you provided this information?  Some of these programs are required by OSHA, the Government (both federal and state), and others may be required by industry standards.

This may not be as scary as it sounds.  Many of these written programs may actually be included as part of your employee handbook – although for various reasons, I suggest that some of the more extensive and detailed programs be external from that document.  Examples of required written programs include:

·         Blood Borne Pathogens – This is not strictly for healthcare but required for anyone who may reasonably come in contact with potentially infectious materials (blood, bodily fluids, etc).  

·         Emergency Action Plan – Where do your people meet if you have to evacuate in the event of a fire?  Where do you go in the building if there is a tornado?  How do you make sure that you get all employees and non-employees (clients, shoppers, etc) out of the building?

·         Hazard Communications – What chemicals are found in your building and do your employees know how to properly handle them?

·         Lockout-Tagout – How do you safely control hazardous energy ranging from electricity to gravity (what if you have to work underneath an elevator?)

·         Personal Protective Equipment (PPE) – This ranges from safety boots for construction workers to face shields for hospital lab personnel.

·         Toxic hazards – Does your company work with formaldehyde, lead, or cotton dust (all considered hazardous by OSHA and the EPA)?  If so, you need to have a written program detailing processes and procedures including required PPE’s.

·         Interestingly, a written “safety program” isn’t required to be in writing except by individual industry mandate.  However, providing a safety program can help you outline that horseplay and other “accidents waiting to happen” will not be tolerated.  Other strongly suggested written programs include new employee orientation plans, job safety analysis programs, and a written return-to-work program.

Now the big question – is the government going around checking to see if I have my written programs and fining me big bucks if I don’t?  In most cases they are not.  Unless you are in an industry that is targeted for spot-checking by OSHA or some other agency, it will never be known that you don’t have your required written programs.  But just like driving without a license (or insurance), you will do ok until you get stopped for a minor traffic infraction (or worse – a major accident that you caused) and then you will be under the magnifying glass.  Spending a few hours and a few dollars up front can be the difference between an incident being classified as an accident and being classified as willful negligence.

Focus1 provides outsourced services in the areas of Human Resources (HR), Benefits Administration, Payroll, Workers’ Compensation (WC) and Safety.   We focus your employee needs so you can focus on your business.