The Occupational Safety and Health Administration (OSHA) has proposed updates to its voluntary Safety and Health Management Program (SHMP) guidelines, which were originally published in 1989. The revisions to the guidelines were crafted on the basis of OSHA’s experiences with its Voluntary Protection Program (VPP) and Safety and Health Achievement Recognition Program (SHARP), as well as from similar industry and international initiatives such as ANSI/AIHA Z10 and OHSAS 18001. 

OSHA and SHMPs

Some states require employers to implement safety and health management programs, but there is no requirement to do so at the federal level. Instead, as it often does when it cannot overcome the barriers to promulgating a new standard, federal OSHA has created a set of voluntary guidelines and is encouraging employers to adopt and implement them as a method of enhancing compliance with existing OSHA standards.

The original SHMP guidelines encourage employers to set up management programs that address: 

Management Commitment and Employee Involvement. This step assigns responsibilities for all aspects of the program so that each employee knows what role he or she is to play in the protection of health and safety. In addition, workers must be given adequate authority to perform their responsibilities and be held accountable for doing so.

Worksite Analysis. This step identifies workplace hazards on an ongoing basis, through baseline surveys, ongoing inspections, accident investigations, and employee reporting systems.

Hazard Prevention and Control. This step implements controls for identified hazards.

Training. This step provides training both for employees, and for supervisors, in hazard identification and control.

The revised guidelines have been expanded to include sections specifically addressing worker participation, program evaluation and improvement, and multi-employer worksites.

In OSHA’s request for comments, which ended February 15, was especially interested in knowing how appropriate and useful the revised guidelines are for small to medium sized businesses. In addition, OSHA asked reviewers to help them identify:

  • Case studies or other documentation that illustrates the effects (benefits, organizational impacts) of fully implementing a safety and health program similar to the program described in OSHA’s guidelines;
  • Inconsistencies between the guidelines and current consensus standards, including ASSE AIHA Z10-2012 Occupational Health and Safety Management Systems standard, or the Occupational Health and Safety Assessment Series (OHSAS) 18001 Occupational Health and Safety Management standard;
  • Workplaces where the guidelines are not appropriate or would be difficult to implement;
  • Tools and resources that could be included as appendices that would make the guidelines more helpful and useful;
  • Obstacles to the implementation of safety and health programs in small- and medium-sized workplaces;
  • Information that would persuade small- and medium-sized businesses to adopt safety and health programs; and
  • Opinions on whether a stakeholder meeting would be beneficial in further revising and finalizing the guidelines.

New Focus Areas for SHMP

According to OSHA, changes to the guidelines include:

  • A proactive approach to finding and fixing hazards before they cause injury, illness, or death
  • Improved safety and health in all types of workplaces
  • Help for small- and medium-sized businesses to effectively protect their workers
  • Increased worker involvement, so all workers have a voice in workplace safety and health
  • Better communication and coordination on multiemployer worksites

What does OSHA mean by each of these statements?

A proactive approach. This is more a change in wording and emphasis than a change in actual recommendations or methods. OSHA has always included worksite analysis and hazard prevention and control in its SHMP recommendations; now, it more explicitly identifies these as proactive rather than as reactive efforts to identify and control hazards.

All types of workplaces. Again, this is more a semantic change than a practical one. OSHA emphasizes in the revised document that it is attempting to create guidance that will work for employers in a broad range of industries, as opposed to focusing on (for example) manufacturing, construction, or chemical facilities.

Small to medium sized businesses. OSHA has made a deliberate attempt to tailor this guidance so that it is useful to small to and medium sized businesses, expressing a desire that these businesses be able to implement the guidelines fully without having to employ outside consultants or other experts. In its original document, OSHA downplayed the need for formal, written SHMPs in smaller workplaces. In the revised document, OSHA acknowledges that very small businesses may accomplish some of the program goals informally but emphasizes the need for employers of all sizes to have a thorough SHMP in place.

Worker involvement. This is one of the greatest changes to the guidelines. The earlier guidelines lumped management commitment and employee involvement into a single program element, but its eight recommended actions were tightly focused on management rather than employees. The revised program breaks worker participation into its own program element, with five action items specifically focused on worker involvement. It emphasizes that workers and their representatives need to be involved in all aspects of the program. It also emphasizes that all workers, including contractors and temporary workers, need to understand their roles and responsibilities under the program.

Multiemployer worksites. Another new entry in the revised document is a section on SHMPs and multiemployer worksites. The section includes recommendations for implementing all aspects of an SHMP on a worksite where the employees of more than one worker are present. It includes recommendations for coordinating work planning and scheduling to resolve conflicts that could impact safety and health and for ensuring that all workers are informed about hazards at the worksite.

For more information or assistance with your Environmental and Health & Safety regulatory compliance needs, contact Ralph Carito at Total Environmental & Safety, LLC (Total) at rcarito@TotalEnviron.com or 908-442-8599.