Water Well Journal

June 2016

Water Well Journal

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The work environment at multi-employer worksites creates a need for additional measures to ensure hazards are identified and assessed and that injuries, illnesses, and incidents involving temporary and contract workers are reported and investigated. Multi-employer worksites create a special opportunity for management and employees to reexamine their policies and procedures, going through each of the core values to ensure they are understood and applied. Reaction to the New OSHA Rules A comment period of several months ended in February 2016. It allowed employers and interested stakeholders in the safety community to comment on the revamping of the 1989 management guidelines into these new guidelines. In the Tool- ing Up section you'll find a transcript featuring the comments as well as the testimony presented for and against the rules. "These rules are a re-jiggered version of rules that have been out a long time and have served as a template for new companies or those in crisis," says Gary Winn, a professor of industrial and management systems engineering in the safety management program at West Virginia University in Morgan- town, West Virginia. "On the other hand, OSHA seems a bit less concerned about enforcement and more about employee involvement in the last decade. As a stellar example, look at what OSHA is doing for fall protection awareness. It's an effort to communi- cate supervisor to worker and to take some time to think about the seriousness of falls, especially in construction. Nothing disciplinary, nothing pro-labor, or anti big government—just a frank discussion about how not to get killed." Your Business and the New OSHA Rules OSHA stresses in the Guidelines the action items in the document are not prescriptions to be followed to the letter; they are merely guidelines to help businesses provide a safer work environment for employees that will help the business in the long run by reducing costs and reducing worker injury. In small business, employer-employee relationships turn more familial, and no one wants to see a family member get hurt. OSHA understands this and writes on it. "Small employers may find that they can best accomplish the actions outlined in these guidelines using informal com- munications and procedures," it states in the Guidelines. The implementation process will vary from business to business and rely heavily on worker participation because some action items "rely on expertise and input that can come only from workers and worker representatives." In addition to using the Guidelines, small business employ- ers have the option of requesting help directly from OSHA through its on-site consultation program, where representa- tives from OSHA come to the small business and help man- agement recognize issues that need to be addressed. This is done outside of the inspection process and partici- pation gives the business a one-year exemption from inspec- tion. Also, once this business has gone through the voluntary on-site consultation program, they are eligible to participate in the Safety & Health Achievement Recognition Program (SHARP), which "singles you out among your business peers as a model for worksite safety and health." The new OSHA guidelines were developed in part after studying the achieve- ments of several SHARP participants. Even though the rules have not been fully adopted yet, most companies already have many of these new core princi- ples in place. This is especially true if you've worked with larger companies in the oil and gas or municipal sector, where safety is a priority. If you are just getting started, OSHA's vol- untary on-site program is ready with offices all over the coun- try to guide you through the safety management process. No matter how big or small your company is, these new rules reinforce it's always smart to think safety first. WWJ Lana Straub, with a background in the legal and financial aspects of small business, is the office manager of Straub Corp., Stanton, Texas, an environmental and water well drilling firm owned and operated by her family for more than 50 years. She can be reached at Lana@Straub Corporation.com. Tooling Up Draft Safety and Health Program Management Guidelines Document www.osha.gov/shpmguidelines/SHPM_guidelines.pdf OSHA On-Site Consultation www.osha.gov/dcsp/smallbusiness/consult.html OSHA Safety & Health Achievement Recognition Program (SHARP) www.osha.gov/dcsp/smallbusiness/sharp.html Safety and Health Program Management Public Meeting Transcript www.regulations.gov/#!documentDetail;D=OSHA-2015- 0018-0109 OSHA from page 25 26 June 2016 WWJ Once a safety program has been put in place, the work isn't finished. The program should be reevaluated on a regular basis to ensure it's up-to-date and meets current safety needs. Build Your Company-Specific Safety Manual You can build a company-specific safety manual with NGWA's Model Environmental Health and Safety (EHS) Manual–CD. It provides a complete safety program manual for those working in the groundwater industry and can be viewed on a computer or printed and stored in a three-ring binder. It also contains a version you can edit so you can add specific company information. NGWA's 18-page Employee Safety Manual handbook is a companion to the Model Environmental Health and Safety (EHS) Manual–CD and covers 30 safety-related topics. Both are available in the NGWA Bookstore at www.NGWA.org. waterwelljournal.com

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