Photo – OSHA
Every once in a while Circle Safety gets a follow-up question after one of our site hazard audits. It usually goes like this – our client’s representative walks around with us and we all note minor and major issues as well as obvious disregard of company safety policies – some or all of which may be violations of OSHA standards. Later, that rep calls or emails, saying there has been some pushback concerning one of our recommendations. Someone is now insisting that we support our recommendation with a reference to a specific OSHA standard.
It’s interesting to note that we are not being asked to give citations to all of our recommendations for improvements – just to someone’s special issue. No problem. We can usually dredge up some reference from OSHA to prove our stance to the doubter, even if we have to point to the General Duty Clause or to the VOSH ARM.
But, I always take this opportunity to remind our client that we were walking around making observations based upon common sense, common industrial practices, and their own written company practices. OSHA standards are at the very bottom of our template for a safe worksite. Sad but true.
I call this kind of pushback the “where does OSHA say I have to do that?” trap.
The question shows both a misunderstanding of modern safety management practices as well as a self-limiting mind-set that started almost 40 years ago and is still being passed on. I have some suspicion that the OSHA Outreach Classes maybe maintaining the “where does OSHA say I have to do that?” trap (but more on that later).
While we wait for OSHA to “reset” (and I have faith that will start to happen), I want to remind all safety professionals to continue to update their own organization’s policies and programs to track with the latest US and International consensus standards and to always use manufacturer’s safety guidelines. And, be ready for The Trap Question by having a ready response. Maybe something like “Joe, our company rules go beyond the minimum requirements of law – that’s what you need to focus on.”
Tags: OSHA
