The OSH Act imposes on employers a duty to train employees to recognize and avoid recognized safety and health hazards in the workplace.
Full-bore formal training for the rank-and-file in the dizzying array of OSHA construction standards is problematic. Studies have shown that even the OSHA 10-hour and 30-hour courses have limited effectiveness, among other things because these (as well as many programs designed by safety consultants) assume a higher level of sophistication than the attendees possess, and befuddle many of them with an excess of jargon, acronyms, and "buzzwords." A further problem is that many construction workers, in the New York metro region as in many other parts of the country, have limited proficiency in English.
OSHA compliance is important, but the paramount goal of your company’s safety program is not to avoid OSHA citations, but to minimize injuries and job-related illness among your workforce. While there is no comprehensive "one size fits all" strategy, elements I recommend for consideration include the following.
First, without suggesting that you forego efforts to train all your workers, I believe it gets you more "bang for the buck" to hire, strive to retain, and train thoroughly field supervisors in OSHA compliance and construction safety.
Second, while you can be cited for any of scores of distinct construction hazards, a relative handful of dangers account for most deaths and serious injuries (and most OSHA citations, as well). Fall protection, scaffolding, excavations, "caught-between" and "struck-by" hazards, unsafe ladders and usage of ladders, and electrocutions are the primary construction safety issues. Nearly every construction employer will be cited by OSHA from time to time, but your employees’ onsite conduct, in recognizing and avoiding the hazards mentioned, is probably the best indicator of whether your company is a safe place to work.
Conversely, you can spend on glossy manuals and consultants, but if your employees work on elevated surfaces without tying off, or go down into unshored trenches, you’re not getting the job done.
An indispensable element to safety success is leadership. Everybody in your employ should be absolutely convinced that his or her safety is a major concern of ownership and management. This implies that supervisors will be knowledgeable concerning OSHA requirements, but also that they be encouraged to call out, and to discipline, workers who disregard safety rules.
A fundamental part of every company’s safety program is so-called "toolbox" (or "tailgate") meetings, at which safety issues are discussed. Such meetings should not only not be neglected, but they can be done in a way that imparts important information, while stressing a genuine concern for worker safety, or in a way that suggests that you are just going through the motions.
Toolbox meetings should be kept short (5 to 15 minutes) but they should not be done perfunctorily. The beginning or end of the work day is generally the best time to have them. After everyone has clocked in on the morning of the first workday of the week is probably ideal. The meeting should be held in a comfortable area where the presenter can be heard, and extraneous noise and distractions are at a minimum. Whether to have such meetings with your entire workforce, or in small groups of workers who work together, or perform similar tasks, is a judgment call that should take into account many factors, to include logistics, scheduling conflicts, potential language issues, and the desirability of getting employees actively involved in the discussion.
Every toolbox meeting should be memorialized in writing, attendees’ names should be legibly recorded on a sign-in sheet, and the name of the presenter, and the subject(s) discussed, should be recorded (and don’t forget to write down the date!) These records should be preserved. One reason for them is to document training for purposes of OSHA compliance, but another is that critical topics - such as fall protection and the others mentioned above - need to be repeated, necessitating a record as to when each such subject was last discussed. Additionally, the regular presenter may be unavailable on a given day, or need to be replaced more permanently. His or her replacement should know which topics have been covered.
The best topics are, obviously, ones that are relevant to current working conditions. While hand-outs are a good idea, reading in a flat tone of voice from a manual is not. The presenter should review in advance, and understand, the topic to be discussed. Employees should be encouraged to ask questions, and to recount experiences or observations related to the topic. Questions to which the presenter does not know the answer should be checked into, and reported on at the next meeting. Each meeting should begin with a brief review of what was discussed at the preceding meeting, for the benefit of employees who may have been absent.
Certain topics (medical emergencies in particular) should be gone over briefly, not less than once a month. This will often include reminding employees as to the location of first-aid equipment, how to summon first responders, how to respond to electrical shocks, and the location of fire extinguishers.
In addition to the topics mentioned above, additional topics can be adapted from the OSHA 10-hour materials, or from a wide variety of commercial and online safety resources.
One resource I came across that looks highly useful is the website safetyawakenings.com. That site offers free access to a menu of about 300 safety topics, with short outlines in both English and Spanish. The topics include both general industry and construction topics (wherefore, not all 300 will be useful) and was compiled especially for use in California. Nevertheless, it’s a terrific source of ideas for meetings and hand-outs (and bilingual as well).
Brief toolbox meetings should complement, not substitute for, more in-depth safety training. They’re important, however, both for the information they impart, as well as being a frequent reminder that safety should be kept in mind at all times.