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Safety and Health Management System Worker Participation

In this article we continue examining the elements of a successful safety and health management system. The first element contained two parts: Management Commitment, which we examined last month, and worker participation which is the topic this month.
Workers have much to gain from a successful safety and health program and the most to lose if the program fails. Workers often know the most about their jobs and any potential hazards.A safety and health program will be ineffective without meaningful participation of workers and (if applicable) their representatives in establishing and operating the program.6
Worker participation means that all workers, including contractors, subcontractors, and temporary staffing agency workers:
  • Have opportunities to participate throughout program design and implementation.
  • Have access to information they need to participate effectively in the program.
  • Are encouraged to participate in the program and feel comfortable reporting safety and health concerns.
In addition, management identifies and eliminates barriers to worker participation in the program.
Note: It is a violation of Section 11(c) of the OSH Act for an employer to “discharge or in any manner discriminate against any employee because such employee has filed any complaint or instituted any proceeding under or related to [the OSH] Act or has testified or is about to testify in any such proceeding or because of the exercise of such employee on behalf of himself or others of any right afforded by [the OSH] Act.”
Note: Incentive programs for workers or managers that tie performance evaluations, compensation, or rewards to low injury and illness rates can discourage injury and illness reporting. Point systems that penalize workers for reporting injuries, illnesses, or other safety or health concerns have the same effect, as can mandatory drug testing after reporting injuries. Effective safety and health programs recognize positive safety and health activities, such as reporting hazardous conditions or suggesting safer work procedures.

Action item 1: Encourage workers to report safety and health concerns

Workers are often best positioned to identify safety and health concerns and program deficiencies, such as emerging workplace hazards, unsafe conditions, close calls/near misses, and actual incidents. By encouraging reporting and following up promptly on all reports, employers can address issues before someone gets hurt or becomes ill.
How to accomplish it
  • Establish a process for workers to report injuries, illnesses, close calls/near misses, and other safety and health concerns; respond to reports promptly. Reporting processes may have an anonymous component to reduce any fear of reprisal.
  • Empower all workers to temporarily suspend or shut down any work activity or operation they feel is unsafe.
  • Involve workers in finding solutions to reported issues.
  • Emphasize that management will use the reported information only to improve workplace safety and health, and that no worker will experience retaliation for bringing such information to management’s attention.

Action item 2: Encourage workers to participate in the program

By encouraging workers to participate in the program, management signals that it values worker input into safety and health decisions.
How to accomplish it
  • Acknowledge and provide positive reinforcement to workers who actively participate in the program.
  • Maintain an open door policy that invites workers to talk to managers about safety and health.
  • Encourage workers to make suggestions about safety and health.
Note: At many worksites, contractors, subcontractors, and temporary workers work alongside regular workers. It is important to encourage such workers to fully participate in the safety and health program. This will allow all workers at the site to benefit from the program and to contribute their insights to make the program more effective.

Action item 3: Involve workers in all aspects of the program

Including worker input at every step of program design and implementation improves your ability to successfully identify the presence and causes of workplace hazards, creates a sense of program ownership among workers, enhances workers’ understanding of how the program works, and helps sustain the program over time.
How to accomplish it
Provide opportunities for workers to participate in all aspects of the program, such as:
  • Developing the program.
  • Reporting hazards and developing solutions that improve safety and health.
  • Analyzing hazards in each step of routine and non-routine jobs, tasks, and processes.
  • Defining/documenting safe work practices.
  • Conducting site inspections.
  • Developing and revising safety procedures.
  • Participating in incident and close call/near miss investigations.
  •  Serving as trainers for current coworkers and new hires. 
  • Developing, implementing, and evaluating training programs.  

Action item 4: Give workers access to safety and health information

Sharing relevant safety and health information with workers fosters trust and helps organizations make more informed safety and health decisions.
How to accomplish it
Give workers information they may need to understand safety and health hazards.
  • Some OSHA standards require employers to make specific types of information available to workers:
  • Safety Data Sheets.
  • Injury and illness data (may need to be aggregated to eliminate personal identifiers).
  • Results of environmental exposure monitoring conducted in the workplace.
  • Other useful information for workers to review:
  • Chemical and equipment manufacturer safety recommendations.
  • Workplace inspection reports.
  • Incident investigation reports.
  • Workplace job hazard analyses.

Action item 5: Remove barriers to participation

To participate meaningfully in the program, workers must feel that their input is welcome and their voices will be heard. Participation will be suppressed if there is fear of retaliation—for example, if investigations focus on blaming individuals rather than the underlying conditions that led to the incident.
How to accomplish it
  • Ensure that workers from all levels of the organization can participate regardless of their skill level, education, or language.
  • Ensure that other policies and programs do not discourage worker participation (see note on page 8 on incentive programs).
  • Authorize sufficient resources to facilitate worker participation; for example, hold safety and health meetings during workers’ regular working hours.