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September-October 2023

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34 PalletCentral • September-October 2023 palletcentral.com 34 PalletCentral • September-October 2023 palletcentral.com Safety Safety leadership and management is vital to the success of every organization. By Adele L. Abrams, Esq., ASP, CMSP Are You a Safety Manager… T he terms "safety culture," "safety management" and "safety leadership" are often used interchangeably in business discussions, or when addressing challenges with the Occupational Safety & Health Administration (OSHA). But are these different names for the same concept, or are there significant distinctions when deciding how to address occupational health and safety (OHS) programs, staffing and goals? As it turns out, there are subtle, but meaningful, nuances between these approaches. In the end, it comes down to the real question: do you want safety "managers" at your company… or do you want safety "leaders"? Safety management is a term often used in conjunction with safety and health management systems (SMS) and is viewed as an organization- wide process designed to manage safety risk in the workplace. ese SMS can be created to fit any type of business, whether manufacturing, warehousing and logistics, or construction. Effectively implemented, SMS programs can help businesses define how their organization manages risk, identifies workplace risks, and guides toward implementation of effective and appropriate controls. SMS programs can also help identify ways to correct nonconforming conditions and performances, addresses organization-wide communication when it comes to OHS, and can help develop continual improvement processes. Organizations can utilize a consensus standard framework, such as the American approach (ANSI Z10) or the ISO 45001 international standard for OHS management programs. ISO also offers the complimentary ISO 9001 for quality management systems, and the ISO 14001 for environmental management systems. Sometimes adoption of such SMS may be a contractual requirement when doing business with publicly traded companies, especially in anticipation of the Securities and Exchange Commission's pending "ESG" disclosure standards – requiring public facing information to shareholders and the SEC on how companies manage their environmental, societal and governance obligations. OSHA tried, but failed, to realize its objective in past years of codifying a SMS standard (which OSHA called "I2P2" – Injury and Illness Prevention Program – during the rulemaking effort). However, in 2016, the agency did adopt revised guidelines for such systems and now requires adoption of an I2P2 program adhering to these guidelines as a condition for "early release" (after two years, not three years) from MSHA's 2022 Severe Violator Enforcement Program (SVEP). e guidelines have seven components: 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 7. Communication and coordination for host employers, contractors, and staffing agencies As you can see, management leadership is an essential element of the SMS but it is not the program

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