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OSHA’s New Recommended Practices for Safety and Health Programs: An Overview

November 28, 2016

Last month, OSHA released its new Recommended Practices for Safety and Health Programs. This is the first time the guidelines have been updated since their issue in 1989.

This article provides a brief overview of the new recommendations and what they mean for companies. We also highlight aspects of the standards specifically related to housekeeping.

Why the new guidelines?

The past almost 30 years have brought extensive changes to the work environment. And many of those changes have a direct impact on worker health and safety.

OSHA identifies several ways work has evolved over the past three decades, and continues to evolve today. Each of these factors introduces a new and different set of hazards:

  • The economy continues to become more service-based and rely on a more mobile workforce.
  • Many work activities are now automated.
  • The workforce is becoming more diverse.
  • The workforce is aging, and more work is sedentary.
  • There’s increasing awareness of hazards in industries typically considered safe.
  • More work is done on a temporary or contract basis, changing the relationship between employee and employer.

What is the goal of the new guidelines?

The new guidelines aren’t prescriptive. Instead, they provide recommendations for how companies can prevent worker injuries and illnesses from happening.

This shift from reactive to proactive echoes what we’ve seen in several industries. For example, the new Food Safety Modernization Act takes a proactive approach to preventing food safety incidents.

The overall goal of the new safety guidelines is continuous improvement. Employers who implement these practices can expect to see benefits across their business, including higher quality, improved employee morale, and, crucially, a better bottom line. OSHA estimates that businesses spend $170 billion each year on costs related to occupational injuries and illnesses, and that establishing safety and health management systems can reduce these costs by 20% to 40%.

What do the guidelines recommend?

The guidelines are organized around seven interrelated core elements. For each element, OSHA provides action items and suggestions for how to accomplish it.

The 7 Core Elements Action Items
Management leadership
  • Communicate your commitment to a safety and health program
  • Define program goals
  • Allocate resources
  • Expect performance
Worker participation
  • Encourage workers to participate in the program
  • Encourage workers to report safety and health concerns
  • Give workers access to safety and health information
  • Involve workers in all aspects of the program
  • Remove barriers to participation
Hazard identification and assessment
  • Collect existing information about workplace hazards
  • Inspect the workplace for safety hazards
  • Identify health hazards
  • Conduct incident investigations
  • Identify hazards associated with emergency and nonroutine situations
  • Characterize the nature of identified hazards, identify interim control measures, and prioritize the hazards for control
Hazard prevention and control
  • Identify control options
  • Select controls
  • Develop and update a hazard control plan
  • Select controls to protect workers during nonroutine operations and emergencies
  • Implement selected controls in the workplace
  • Follow up to confirm that controls are effective
Education and training
  • Provide program awareness training
  • Train employers, managers, and supervisors on their roles in the program
  • Train workers on their specific roles in the safety and health program
  • Train workers on hazard identification and controls
Program evaluation and improvement
  • Monitor performance and progress
  • Verify that the program is implemented and is operating
  • Correct program shortcomings and identify opportunities to improve
Communication and coordination for host employers, contractors, and staffing agencies
  • Establish effective communication
  • Establish effective coordination

What does this have to do with housekeeping?

While the guidelines and action items are broad, many of the specific ways to accomplish the action items have to do with housekeeping, especially the sections on hazard identification, assessment, prevention, and control.

Hazard identification and assessment

OSHA states that housekeeping hazards “can and should be fixed as they are found.”

Identifying and assessing hazards includes monitoring worker exposure. They recommend conducting quantitative exposure assessments when possible, using air sampling or direct reading instruments. Learn more about the air sampling and exposure requirements of OSHA’s new silica dust rule.

The agency recommends using checklists to identify typical safety hazards in common categories, including general housekeeping and fire protection.

Hazard prevention and control

Once you’ve identified the hazards present in your facility, you can control them. OSHA recommends selecting controls according to a hierarchy that puts engineering solutions at the top and personal protective equipment (PPE) at the bottom.

This is in keeping with OSHA’s recommendations for controlling specific hazards. For example, PPE is considered a last resort for controlling both toxic substances in active pharmaceutical ingredients and silica dust.

The guidelines also advise avoiding controls that may introduce new hazards, either directly or indirectly. One example they give is “exhausting contaminated air into occupied work spaces.” A vacuum cleaner with multi-stage filtration — including a downstream filter that keeps contaminants in, rather than exhausting them back out again — can help you accomplish this goal.

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OSHA’s Recommended Practices for Safety and Health Programs aren’t mandatory and you can’t be cited for not implementing them. But by putting these practices in place, you can protect yourself from the serious fines associated with safety violations. In addition, the agency’s assistant secretary of labor David Michaels said that “employers who [show] a good-faith effort could receive a reduction in penalties.”

If you’re ready to take your housekeeping efforts to the next level through a proactive approach contact a Nilfisk representative. We’re here to help.

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