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28 PalletCentral • May-June 2022 palletcentral.com 28 PalletCentral • May-June 2022 palletcentral.com What about the rank-and-file worker – do they have a role in building and maintaining a strong safety culture? Absolutely! Workers have an obligation to stay informed of conditions affecting their health and safety. Upper management must commit adequate resources to maintaining and improving occupational health and safety systems and performance. When safety audits identify the need for more training, or replacement of unsafe equipment or machinery, the commitment of resources must be in place: otherwise, the audit becomes a paper trail that OSHA can use for willful citations. Senior level officials can also assist supervisors in conducting workplace hazard assessments to identify, evaluate, and correct hazards, to gain first-hand knowledge of how processes work and what the unique safety challenges are in the specific workplace. Upper management also oversees the training and technical assistance afforded to managers and supervisors on system implementation, review, update and evaluate the overall effectiveness of the program; and, ultimately are responsible for evaluating the adequacy and consistency of training and controls designed by internal departments or provided via third-party consultants. On-site supervisors have a full plate of safety-related responsibilities, in addition to overseeing operations and meeting production goals. ey must ensure that workplaces and equipment are safe, well- maintained, and in compliance with external (governmental and consensus) regulations, with the company's internal safety and health management system, and with the corporate policies, programs, and practices. is is not a paper chase, however. Supervisors must actively ensure that workplace safety and health practices and procedures are clearly communicated and understood by employees through training programs, and perform sufficient observation to be sure that appropriate practices and use of PPE are followed consistently. e supervisor must also enforce rules fairly and uniformly, related to job performance, and acknowledge workers who make significant contributions when it comes to maintaining a safe workplace. Where discipline is required, it must be fair, appropriately documented, and must follow established protocols or progressive discipline system. Supervisors should also encourage employees to report workplace hazards and "near misses" without fear of reprisals (and supervisors or in-house OHS staff must investigate all such incidents). Finally, supervisors are responsible for maintaining systematic workplace inspections, so that identified safety deficiencies can be corrected in a timely manner. What about the rank-and-file worker – do they have a role in building and maintaining a strong safety culture? Absolutely! Workers have an obligation to stay informed of conditions affecting their health and safety; participate in training programs and safety committees (where applicable), and participate in OSHA inspections (they have the right to speak privately to inspectors, without management or counsel present). Workers must follow safe and healthful practices in their workplace, and raise safety and health concerns promptly (aware that they are free from fear of retaliation). Workers must also promptly report potential hazards in the workplace, "near miss" events, injuries and/or accidents, so that they can be investigated (without retaliation) by management and appropriate mitigation put in place. How can an employer get started on a workplace safety and health management program (SHMP) that can improve the company's safety culture. OSHA encourages implementing such programs (sometimes called I2P2, or "Injury & Illness Prevention Programs") and, in 2016, revised its guidelines for developing SHMP. ese are not enforceable at the present time, although OSHA did consider development of an I2P2 standard during the Obama administration, and the rule could return to the agency's agenda in the future. e revised OSHA guidelines include the following seven elements: 1. Management leadership; 2. Worker participation; 3. Hazard Identification and Assessment; 4. Hazard Prevention and Control; 5. Education and Training; 6. Program Evaluation and Improvement; and 7. Coordination and Communication on Multi- employer Worksites. Clearly, OSHA's components for a strong SHMP echo the elements of a strong safety culture. In addition to using OSHA's guidelines as a model, companies can also look to SHMP consensus standards as a blueprint, including the ANSI Z10- 2019 standard and the international version, ISO 45001. e OSHA guidelines, and other information on building a strong safety culture, are available at: https://www.osha.gov/safety-management. While OSHA sometimes requires adoption of SHMP as part of corporate-wide settlement agreements, it is clearly more beneficial to proactively improve your safety culture now. e cheapest citation to defend is the one that is never issued! Adele L. Abrams is an attorney and safety professional who represents companies in litigation with OSHA and also provides safety training and consultation. The Law Office of Adele L. Abrams PC has three offices: Beltsville, MD; Denver, CO; and Charleston, WV. She may be reached at www.safety-law.com or 301-595-3520.

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