OSHA citations can be costly. You might pay fines, have to scramble to meet the inspector’s demands in a very short time, experience operational interruptions, see an insurance rate hike, and witness talented employees look for employment where the safety record is better. Here are five tips to help prevent these citations.
Tip No. 1: Forget about OSHA citations. It’s not really about the citations — it’s about the deficiencies in policy, training, execution, and supervision that result in citations. Begin by examining your safety program. Does it meet all OSHA criteria? Make sure it does, and not by stretching the truth. You want to meet the intent of the criteria, not just the bare “letter of the law.” Once you prove your program is rock solid, move on to how well it is communicated to the employees. Keep going with this modular approach to finding and fixing weaknesses.
Tip No. 2: If you’re caught, take ownership. Admit the mistake, apologize for the mistake, thank the inspector for finding it, and promise to implement a fix pretty much right away. For example, an OSHA inspector noticed people were not clipping into proper attachment points while at elevation. There wasn’t a problem with the safety program, but there was a problem with the training. Some workers assumed they needed to clip in only if reaching over the edge of the platform. Others were wrapping their lanyard around a pipe and clipping to the lanyard itself to make a loop. Still others were clipping to the bottom rail of a lift, putting them above the point of protection (which is dangerous).
If the inspector sees you are making excuses rather than showing a sincere desire to improve safety, you give the inspector motivation to continue looking for violations and/or to come down hard on you with each citation.
Tip No. 3: Conduct your own audits. A savvy safety director in a three-shift manufacturing plant in Tennessee took two weekly safety tours through the plant. One tour was with either a department manager or a maintenance manager. His purpose wasn’t so much to find safety problems, but to show these managers what to look for. The other tour was by himself, and he would look for specific things that might result in an OSHA citation if an OSHA inspector ever visited. He had a list of what to look for, and he modified it every so often. Rather than look for the same things every time, he’d drop one and add another.
Tip No. 4: Look for unsafe acts. OSHA cites companies, not individuals. So, why do this? Unsafe acts are visible signs that you may have citable deficiencies. They could also be signs that you have a weak safety culture, and that kind of weakness makes your safety program shaky at best. If unsafe acts are focused in one department or among a few individuals, the problem is likely a poor attitude toward safety (or it could be poor circumstances, such as the wrong ladders are provided). Don’t let poor attitudes metastasize; have conversations with the employees and their supervisors to set expectations and meet any training or equipment needs that contribute to the problem.
Tip No. 5: Highlight safe acts. When you commend individuals and their supervisors (and maybe their departments) for safe acts, the positive reinforcement isn’t just about those particular safe acts. You are telling people they are appreciated for working safely. You are reinforcing the thinking behind those safe acts.
Elaborate praise isn’t needed. A wordless thumbs up can be very effective. When the plant engineer tells the maintenance manager that the electricians did a good job of safely removing the old drive motor on Line 3, what happens? Word gets passed down that safe behavior reflected well on the department. Managers at all levels can provide positive reinforcement, even without directly speaking with the involved crew members. Of course, direct praise or approval is also good.
By also noticing when people are doing things right, safety is spared the fate of being “something you get busted for.” When people have a safety mindset, they are also going to tell their management about safety problems that need management attention. Often, these are the very things that OSHA writes citations for.
