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Writing A Safety Policy

A step-by-step guide for keeping your number one asset safe.

At a material handling distributorship, employees are often in dangerous or physically demanding situations where attention to safety is critically important. With the cost of Workers’ Compensation today, it’s essential—even for small businesses—to have policies in place to mandate safe behaviors by employees.

Some safety rules, such as the Powered Industrial Truck Operator Training rules, are laid out specifically by the Occupational Safety and Health Administration (OSHA). Others, such as vehicle fleet safety and emergency action plans, are up to the individual dealership. Many sample safety plans can be found online or through your insurance company to give you a good starting point to write your program.

Whether you use a template or decide to write the plan yourself, your safety policies should have many of the same elements. All policies at our company follow the same standard format:

Purpose — The first step is to define what you want the policy to accomplish. What behavior are you trying to prevent or encourage?

Scope — Identify who will be affected by this policy. Is it only for service technicians? Does it apply to all office personnel? All employees?

Roles and Responsibilities — For each employee position that is impacted by the policy, define that individual’s roles and responsibilities for implementation. A service tech has a different role than a department supervisor, who has a different role than a general manager.

Our company, for instance, has a policy regarding the use of personal protective equipment (PPE). The general manager’s role and re-sponsibilities include authorizing PPE purchases, requiring managers to evaluate job tasks by using our specialized needs assessment form and requiring managers to conduct annual PPE training. The department manager has a bit more responsibility—conducting an assessment of job tasks; completing the required PPE checklist; and training employees on how to inspect, use and clean PPE. The safety manager is responsible for establishing the company’s PPE requirements, and approving or rejecting completed PPE needs assessment forms. The more in-depth a program is, the more people it will involve.

Training — Each policy should contain a training section that outlines what kind of training is needed and how often it should take place. This section of the policy doesn’t necessarily need to be extensive. For example, our PPE policy simply says, “Training will occur prior to the employee engaging in work where PPE is required,” followed by an outline of what the training will cover and who will conduct it. Be sure to include any special requirements.

Actions — The actions section establishes what must be done to get the program going. For our PPE policy, the actions include: “The department manager will arrange for an initial valuation of each job task for potential hazards” and “Afterwards, the supervisor shall evaluate all subsequent changes” and so forth.

Documentation — This section of the policy states what documentation, if any, is required by OSHA and where it’s going to be stored.

Developing a Policy
Our company has six locations in four states, and each location has a safety committee to address safety concerns that come up at each site. Employees encounter issues and bring them to the attention of that location’s committee, which then makes recommendations to the safety manager for creating a company-wide policy. Our policy development is driven by the committees.

If the policy isn’t in writing, people don’t take it seriously.

For example, we recently implemented a toolbox weight restriction after multiple field technicians were injured carrying overstuffed toolboxes. They didn’t want to make two trips to the truck once they arrived at a customer site. To avoid more injuries, we decided to create an official policy. If it’s not in writing, then people don’t take it seriously. To emphasize it even more, our field service managers are going to periodically check toolboxes in the field using scales in their vans.

Once a policy is created with all the required sections, the next step is to distribute it to everyone. If it’s something simple, we often just attach it to employees’ paychecks, post a memo or drop it in their mailboxes. If the policy requires more in-depth training, then we bring it up at a company-wide meeting or set up a teleconference to involve people at the other locations. The toolbox weight policy was introduced as part of Saturday morning technician training. Technicians had a chance to learn about the policy firsthand, weigh their toolboxes (and remove some weight if necessary) and sign off that they received the training. The bigger the change, the more we emphasize it to make sure the point is driven home.

Soliciting Feedback
OSHA’s Top 10 Most-Frequently Cited Standards in Fiscal Year 2009Developing a viable safety policy can be a time-consuming process. The timeline varies depending on who has to authorize what and how many people need to be involved, but generally it takes about two months for a policy to be brought up in a committee, written and modified. After a policy is written, it gets presented back to the individual committees for feedback. Once that is settled, the policy gets distributed to employees and then officially implemented.

During that two-month window, try to solicit some feedback from the employees. You don’t want to push out a policy that isn’t feasible or isn’t helpful. Most of our managers have worked in the field, so they can often anticipate what people are going to say. We also ask the employees affected by the policy what they think of it. The last thing we want is some people sitting in an office determining what’s best for people in the field. Employees aren’t likely to follow a policy if it doesn’t make sense for them, and then you haven’t achieved anything. Of course, some people will gripe about any change, but overall, if most people agree with the policy, then that’s the route we take.

If you take nothing else out of this article, take this: Get as many people involved as possible. It is tough for one person to sit there and try to write a policy from scratch. It just doesn’t work. It needs to be a cooperative effort.

Enforcing your Policy
Don’t write a policy just to say you have one. If that’s your reasoning, then there’s no point putting it in writing. Our insurance company actually told me that it looks worse to have a policy and not enforce it than to not have a policy at all.

Enforcement is everybody’s responsibility. The safety manager can’t be out in the field, checking dozens of technicians across multiple states. We rely heavily on our field service managers to conduct periodic checks to make sure that our employees wear their PPE and do not overload their toolboxes, among other things.

If we do notice someone doing something incorrectly, we have corrective action guidelines in our policies as well, using the hierarchy of verbal reminder, written warning, suspension and ultimately dismissal. The manager should directly address the improper behavior when it occurs. If it happens again, it’s up to the manager’s discretion as to whether to issue a verbal or written warning, depending on the severity of the violation. In rare cases, severe violations that put an employee’s life in danger may call for automatic dismissal, and that is stated in the policy.
The entire safety manual is audited at the end of every year. If we feel we need to revise a certain policy based on anything that came up during the year, we do it at that point.

The strategies laid out here are what work for us at Associated Material Handling. Hopefully, they work for you to keep your most important asset—your people—safe.

Material Handling Equipment Distributors Association
Rudy Cuevas Meet the Author
Rudy Cuevas is corporate safety administrator at Associated Material Handling, located in Addison, Illinois, and on the Web at www.associated-allied.net.

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