I’m finishing up a review of a client’s safety policies and procedures, and it got me thinking – why do we even have manuals? I’ve done a number of these reviews and read a lot of manuals. I’ve decided it is time to rethink how we manage our policies and procedures. We still need manuals but there is a real need for companies to think through what their purpose is and whether our existing documents meet that purpose. Here are a four key issues to consider:
Safety manuals tell your story, but what story do they tell? A few years ago, I got a call from a company that said its manual needed tweaking. What I found was a monster that took up two massive binders, with loose pages stuck in here and there. It had been added to, revised and updated until it contained about two feet of gibberish. Most of it only existed as paper copies with no electronic versions.
Was the company safe? Based on the knowledge and hands-on work of its safety director and its incident record, the answer would probably be yes. However, a customer or regulator might have taken one look at the manual and reached a different conclusion. In fact, the company was having a hard time satisfying customer requirements for safety or quality management systems, despite a good safety record.
Is it time to take a hard look at your safety manual? Contact us at email@example.com. We can help align your policies and procedures to your scope of work, keep you compliant with regulations and in tune with evaluation services like ISNet, and make the step from a manual that sits on the shelf to a fully functioning safety management system. We also offer safety services to companies that can’t afford a full-time safety department.
Bigger doesn’t mean better. In the case of the company above, they originally bought a generic, off-the-shelf manual from a vendor that had no relationship to their industry or internal processes. It used job titles and positions the company didn’t have. It was based on OSHA Construction Standards, even though the company fell under the General Industry Standards.
As the company needed new procedures, or regulations changed, new versions were added, sometimes by literally cutting and pasting pieces of paper onto the original. Someone had added a few plain English versions to share with the crew and those went into the binder. Finally, there were a whole different set of policies to meet ISNet and other third-party evaluator requirements. Many of them applied to types of work the company never did, but they went into the binder too.
Safety isn’t judged by the weight of a manual or how many feet of shelf space it takes up. It is judged by the ability to identify hazards specific to a company’s scope of work, develop policies and procedures to control them and implement them where the hazards actually occur – in the field.
Did you know there is something called “Google?” Frequently you see manuals that read like the Federal Register. That’s because they duplicate whole sections of the OSHA or EPA regulations word-for-word. Why? In the old days, maybe it made sense to include the original language as an easy reference. Today, the original documents and reputable interpretations are available with a few keystrokes. So why do you need five pages on medical surveillance, lifted directly from the regulations? Including the title or a hyperlink to an OSHA or ANSI standard makes sense, but that is as far as it goes.
What Is your manual for? There was a time when simply having a manual showed you were ahead of the pack on safety, but that was a very long time ago. Now, the measure of a good manual is how well it integrates into your overall safety program. My suggestion is you set the following goals for your manual:
- It should be relevant to the actual hazards your workers face. If you run a tank cleaning company, you need appropriate, effective confined space policies, but if you if your never do scaffolding, do you need 15 pages on scaffolding?
- It should set the tone internally and with customers. Well-written policies and procedures, vetted with company executives and operations managers, establish the way the company will manage safety. It is a lot harder to argue with something that is in writing and has upper management buy-in.
- It communicates safety to the field level. Plain English please! The manual should lay out the way safety will be implemented on the job so that everyone can understand it. If it is confusing or full of errors, no one will pay attention to it. A common error is to throw out a manual that refers to managers by the wrong labels, such as Superintendent when the company doesn’t use that title. Think about it – if you send out a document that is inaccurate, sloppy or describes processes no one ever uses, why should your crews take your safety message seriously?
- It keeps you out of legal trouble. A manual can save you in a lawsuit if it is accurate and compliant with the regulations and standards that apply to the company. One of the most effective company defenses if a supervisor violates policies is to have written policies and documentation that shows when the supervisor was trained on them. On the other hand, it can be a smoking gun for a plaintiff’s lawyer if it violates regulations or industry standards, or outlines policies that are routinely ignored (that cellphone ban, if the company doesn’t enforce it for everyone.)
- It drives the overall safety management program. Having policies and procedures is not the same as having a safety program. Integrating them into a management framework is the foundation of a safety program. Identifying and controlling hazards, integrating training and then having a mechanism for constant improvement starts with clear, concise policies and procedures.