Issue link: http://palletcentral.uberflip.com/i/1511664
38 PalletCentral • November-December 2023 palletcentral.com Safety By Adele L. Abrams, Esq., ASP, CMSP Succession planning in safety ensures the continuity in training and a smooth transition in processes and procedures. S afety may be a core value with many companies, but too often, when corporate succession plans are made, transitions of a company's occupational health and safety (OHS) leaders can get overlooked, with disastrous results. A recent survey by the National Safety Council found that only 25 percent of their members had a succession plan in place for the occupational safety and health functions. However, data also show that employers who engage in succession planning in the safety arena fi nd that it helps workers develop new skills, limits workplace injuries and improves the bottom line. Some transitions in the safety department are foreseeable, especially where retirement is involved and there is time to overlap between the old and the new offi cers. Some transitions are abrupt – due to fi ring, quitting, serious illness, or sudden death. ose are the situations that are most likely to leave a company in the lurch in terms of program and training continuity and can lead to OSHA citations and even tort exposure. Sometimes, companies can be crippled by simple things such as not knowing the passwords needed to access OSHA portals or to get into company fi les on a PC or server, or to deal with safety vendors. In one case I handled, after a fatal accident the safety director disappeared (perhaps out of fear of criminal prosecution) and when he left, he deleted all of his fi les from his company computer. As a result, not only were the programs unavailable to share with OSHA during the investigation – since this was a largely "paperless" offi ce – but the training given to the deceased temporary worker was similarly unable to be documented. As a result, the host employer received a signifi cant OSHA penalty, and also faced breach of contract and wrongful death charges arising from their failure to demonstrate that the contractually required training for the temporary worker had been provided. e takeaway from that situation was that it is critical to maintain hard copy fi les of training documentation, in addition to computer records. A second lesson learned was that all safety records should not be under the control of a single individual, redundancy is needed to make sure critical items can be located in an emergency. Succession planning in the safety silo is critical because of the complexity of OSHA compliance, the many written programmatic requirements – some of which must be revisited periodically, such as annual review of lockout/tagout protocols. OSHA has scores of training requirements, some of which are subject to refresher training on varying timetables, some which have document retention requirements. is link is to an OSHA booklet capturing the key training and documentation requirements that employers must SAFETY SUCCESSION SUCCESS Requires Planning