A movement within the safety community, primarily online banter, somehow finds fault with a WRITTEN safety management system (SMS). There are even books published on the topic that are being pushed, decrying written programs as a bureaucratic waste of time, too controlling, no value added, etc. I find this very sad, but they do have a point. Most written safety programs are written as COMPLIANCE (check-the-box because OSHA says I have to have a written program) style programs that do NOT add value to our safety efforts. However, a well-written safety management program that explains the WHYs and HOWs of controlling the recognized hazard the program is written for is foundational to any mature SMS. The problem is not that the program is written; the written programs are most often a simple regurgitation of the OSHA standard, and this does little to nothing for the safety of employees. A few weeks ago, I wrote a post about the difference between a “compliance program” and using the SMS approach for our written programs. For these programs to add value and be a useful resource to the non-safety professionals within the organization, we MUST explain the WHYs and HOWs of controlling the recognized hazard.
When a client reacts to my 70+ page Lockout or Confined Space programs viscerally, I immediately recognize their maturity level in safety. They fear this type of program and decry that no one will ever read a 70-page safety program. My response is how many are reading your 1-2 page programs? It is not the LENGTH of the program that measures its effectiveness; it is the CONTENT of the program. How many LOTO or PRCS programs can even be compliant and be less than ten pages is a mystery to me; however, if we merely cut and paste 1910.146 into a WORD document, we can achieve this. But take 1910.146(c)(1) as an example…
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1910.146(c)(1) The employer shall evaluate the workplace to determine if any spaces are permit-required confined spaces. Note: Proper application of the decision flow chart in appendix A to § 1910.146 would facilitate compliance with this requirement. |
It is one thing to state this requirement, but it takes several pages to explain HOW this workplace evaluation must be done in order for it to be done PROPERLY. And this is STEP 1 in our efforts to CONTROL a recognized hazard – if we mess up this step, the entire program/effort to control PRCS hazards fails at some level. And with this type of hazard, we can not afford to have this type of failure.
So if the facility’s written PRCS simply regurgitates this compliance requirement and does NOT specify
