Should you see OSHA as a hostile entity out to reduce your competitiveness and profitability, or is there a way to use OSHA to improve competitiveness and profitability? If the former, then you would play “catch me if you can” games with OSHA and rely on luck to protect your employees. While that strategy is common, it does not produce good outcomes in the long run.
A much better way to look at OSHA is to see its regulations as just another set of industry codes. In fact, if you look at the electrical section [1910, Subpart K), you will see much of it matches corresponding parts in NFPA 70, National Electrical Code. And those matches are verbatim. This came about because for decades until he retired, the OSHA manager for the electrical requirements worked with people in the electrical industry to make it this way. He deferred to the industry people, instead of arbitrarily coming up with non-expert requirements. His successor has kept with this practice.
So now we can turn to the NEC, specifically 90.2, and grab two concepts:
- Practicality. It’s about the practical safeguarding of persons and property, though in the case of OSHA it’s the persons only. It’s not a guide for the untrained, a fact that strongly implies independent judgment beyond the stated requirements. That is, just because OSHA doesn’t explicitly require something doesn’t mean you can pretend it’s not required in reality.
- Adequacy. It’s enough to address the basics for safety. It doesn’t address efficiency or other goals. You can go beyond mere adequacy by instilling methodology into how work is done.
During a panel discussion at an industry conference, a manager for an electrical services firm stated his company doesn’t worry about meeting OSHA regulations. He went on to clarify that his company’s safety policy easily meets OSHA requirements, because it exceeds them “for the same reason we might recommend upsizing a neutral beyond the code minimum.” The reason is to accomplish the goal rather than check off the box.
Some of the thinking behind exceeding OSHA requirements based on actual conditions is it’s better to err on the side of imposing excess safety steps and not need them than to go light and wish you hadn’t.
A question that often arises in regard to this thinking, and even to barebones OSHA compliance, is, “Doesn’t this reduce your competitiveness and profitability?” This question is based on the idea that safety is an extra layer of time and effort that comes at the cost of productive time. But what many companies have found is the opposite is true.
Going back to that manager, he had gone on to say that he can’t remember the last time his company had to return to the job site to do free rework. The reason, he explained, is they have a system for doing the work. And safe work methods are built into that system. Because of good job briefings, well-honed procedures, and methodical work practices, human error has been driven down into the negligible range. And when there is a problem, “we don’t spend all day chasing our tail to figure it out.”
As with any other code, treat OSHA regulations as the minimum needed. It’s worth taking the time to review your safety program and your work procedures for weaknesses in relation to OSHA requirements. Yes, this will help your company avoid being fined. Yes, this will help your company avoid the profit drain caused by inefficient work practices (as opposed to methodical ones). But the big benefit is you take the practical steps necessary to ensure your people are adequately protected from hazards that arise on the job.
