In this profession we have a saying when it comes to written safety programs… “steal with pride”. We learn early on in our careers that not much changes in OSHA standards so finding someone who already has a written program, training powerpoint, permits, checklist, etc. that we can just “steal it” rather than “recreating the wheel”. This practice has been around in profession for as long as there has been a safety profession. There is just one small problem… proliferating bad safety programs is a bad practice!

Recently we were working at a PSM/RMP facility and we can across some documents called Material Safety Data Sheets - do you remember these archaic documents? (LOL) So yes, as auditors we went down that rabbit hole and inquired about why the old MSDS vs. the new SDS layout/document. While looking into their HAZCOM program we discovered the written program was a mess, full of incorrect requirements and missing some significant content.

As it turns out, the facility got the written program from a sister facility, who got the program from who knows where! Not only was the program a problem, the facility was not even managing their HAZCOM program as described in the written program.

So here’s the catch with “stealing with pride”…

  1. steal from a reputable source
  2. know whats in the program your stealing, and 
  3. make sure the stolen program is fully implemented as written (or as revised as needed)

I always had 2 or 3 reliable sources that I would use. I would then compare the programs and any discrepancies/differences I came across I would go back to all three sources and ask for an explanation. This was a great learning opportunity for me and a nice reminder that when managing OSHA requirements there are many options and finding those that are best suited for your facility are key to success.

I am TOTALLY - 100% against using Google to find a “written program” as my experience tells me that the majority of the programs out there are deficient in some manner. Never lose sight of the fact that our written programs are core to our safety efforts. They need to be written in such a way that they provide the required actions and explanations of the “why” we have to do certain actions - NEVER should we say it is OSHA required; we need to explain WHY OSHA requires it. OSHA is like bigfoot to those outside the safety profession… they’ve heard about it and maybe seen a video with OSHA in it, but they have most likely never seen an OSHA CSHO in real life!

This client did a really neat thing to end this bad practice within their organization.  They hired SAFTENG to audit 15 facilities (out of over 100 USA based facilities) Hazcom Program compliance.  This was a deep dig into their recently revised program and practices and what we found was that the entire management system break down began with this sole written program that was shared across the entire organization.  The VP of EHS then put out an edict and formulated a policy about sharing safety materials.  The organization began a review process and then placed written safety materials (programs, permits, training materials, etc.) that were reviewed and approved by the corporate safety team onto the EHS Intranet Page for others to obtain and use.  This was sort of a "clearing house" but ensured that "shared" safety materials had some type of review and approval process.  Now they are just digging out of the hole that was created by their flawed sharing practice and the lack of any internal controls (e.g. auditing program) which should have identified these issues years ago.

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