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Parent Category: Safety Info Posts

Category: OSHA Compliance Posts

Published: 01 September 2023

I know by the poll results and the emails/texts/calls I have received these past 2-3 weeks that this post will be met with a healthy dose of skepticism, but that has never stopped me from saying what I believe when it comes to the safety and health of those we have the privilege to protect.  So, I hope to spark many more discussions with this series of articles titled "Is shorter better?"

I am 100% convinced that the idea of "if we only had shorter written programs that more people would read them" is a pipe dream that has found a strong foothold in our profession. Hell, we visit facilities where safety team members have not read all the written safety programs, so to think that those outside the safety group will sit down and read a program from cover to cover is puzzling to me. 

I have always used the same format, whether a PSM/RMP or a traditional OSH written program, for my programs.  This allows the reader to find the info they seek much easier - rarely having to read large sections of the program to get their answer(s). 

IMPO Written Programs are not intended to be read like books by front-line workers and management.  I do expect that ALL safety team members will read the program's cover-to-cover. Hence, they get a complete understanding of the program and can provide feedback on concerns and opportunities to improve the program.  The written programs are intended to be reference documents; I use them to explain WHY we do what we do to be SAFE (not compliant!).  I still use the OSHA/ANSI/NFPA standards as my foundation for the material in my programs, but I NEVER regurgitate the language of the standard.  Our programs need to EXPLAIN who, when, and how the facility will achieve the standard's requirements and beyond (remembering the standard is often the minimum framework requirement).  

This often means our written program could be 50-70 pages.  However, it will cover every aspect and inform the reader how to perform every piece of the program to execute the program requirements.

For example, if your facility performs entries into Permit-Required Confined Spaces, I will bet the written program will say something like...

Before an employee enters the space, the internal atmosphere shall be tested, with a calibrated direct-reading instrument, for oxygen content, for flammable gases and vapors, and for potential toxic air contaminants, in that order. 

That is a cut and paste from 1910.146(c)(5)(ii)(C).  In this one sentence, there are two (2) safety-critical requirements that many entry supervisors can NOT explain the WHY or HOW.

1) calibrated direct reading instrument (including the meter manufacturer's requirements for daily bump tests)

2) order of sampling the atmosphere within the space

I am sure everyone is training their entry supervisors and safety team members on the calibration frequency, how to perform the daily bump tests (per the manufacturer's requirements), and why we first sample the atmosphere for O2.  But the program is in place for those occasions where we trained them in January, and now it is August, and they will be doing their first entry.  Do we think they may have questions about HOW to perform these tasks?

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