Equal opportunity is an important part of business, and the Americans with Disabilities Act is designed to eliminate workplace discrimination against handicapped individuals.
This program explains how employers can keep themselves legally protected during the interviewing and hiring process, how to write job descriptions that outline the specific functions of the job, and how your workplace can better accommodate employees with disabilities. Learn the law and discover the benefits of hiring without discrimination.
Sunday, January 23, 2011
Wednesday, January 19, 2011
Personal Liability In The Worplace Pranks And Harassment
This is perhaps the most important training on the market today because individuals and employers are targeted for lawsuits, by the individuals who have been harassed or subjects of harmful pranks. Without realizing just how harmful these actions can be to others, victims are striking back, which often lead to great monetary awards and career ending difficulties. Every organization has the liability for making sure the workplace is free of such pranks and harassment, but also to develop a plan that ensures each instance be investigated and action taken to prevent future pranks and harassment. New social media, such as facebook, twitter and youtube can lead to personal liability, even though no harm was intended. Emailing jokes is a fact of life, but when it is disruptive, harmful and hurtful, it becomes a matter for the legal system, if the victim so chooses.
This training program provides examples of such activity, what steps that can and should be taken to prevent workplace pranks and harassment. Millions of dollars in litigation costs, awards and loss productivity are at stake, as much as the deleterious effect on victims. Every employee, supervisor and management should review this program and take action to curtail and eliminate these practices.
For More Info & Free Online Preview Click Here!
Ten Steps to a Safe Kitchen
- Keep your refrigerator at 40° F (4° C) or less.
- Refrigerate cooked, perishable food as soon as possible within two hours after cooking.
- Sanitize your kitchen dishcloths and sponges regularly.
- Wash your cutting board with soap and hot water after each use
- Cook ground beef, red meats and poultry products to a safe internal temperature. Use a meat thermometer.
- Don't eat raw or lightly cooked eggs
- Clean kitchen counters and other surfaces that come in contact with food with hot water and detergent or a solution of bleach and water.
- Allow dishes and utensils to air-dry in order to eliminate re-contamination from hands or towels.
- Wash hands with soap and warm water immediately after handling raw meat, poultry, or fish.
- Defrost meat, poultry and fish products in the refrigerator, microwave oven, or cold water that is changed every 30 minutes.
- Follow package directions for thawing foods in the microwave.
- Cook microwave-defrosted food immediately after thawing.
- Changing water every 30 minutes when thawing foods in cold water ensures that the food is kept cold, an important factor for slowing bacterial growth on the outside while inner areas are still thawing.
Electrical Safety Training - Work Practices
By Charlie Bentson King
Electrical safety training is paramount to a safe and productive workplace. Because electricity is a part of every aspect of a workplace it is imperative that everyone in that workplace understands its safety and use. Just a single electrical accident can be catastrophic. OSHA has made the training mandatory and divides it into three categories - hazard recognition, proper work practices and hazards specific to different work environments.
Work practices start with understanding the most common electrical dangers - shocks, burns and fires - and how to avoid them. Here are some of the major reasons for these dangers and how to avoid them.
Work practices are the second category of training that OSHA requires and an integral part of electrical safety training. Make sure that your organization is up-to-date on electrical safety training. It might just save a life.
Work practices start with understanding the most common electrical dangers - shocks, burns and fires - and how to avoid them. Here are some of the major reasons for these dangers and how to avoid them.
- Faulty wiring causes many electrical accidents. Never pick up a tool by its power cord. It will damage the wire by pulling it away from the tool causing cracks and other defects. Any damages in the cord should be addressed immediately by putting the tool out of service and scheduled for repair.
- Never run too many pieces of equipment on the same circuit. This causes overheating and increases the risk of fire.
- Extension cords are designed for temporary use only and NEVER should be used as a permanent solution. Make sure you always check the extension cord for its rating.
- 3-pronged cords should never be fitted into 2-pronged outlets. This keeps the grounding wire from operating and makes you vulnerable to stray electricity.
- Using "double insulated" tools will provide you extra protection when working with electricity. These types of tools should be mandatory in the workplace as they conduct electricity away from you increasing worker safety exponentially.
- If there is any suspicion of a tool or piece of equipment not operating properly it should be reported immediately to your supervisor who can arrange for it to be locked and tagged.Lock-Out Tag-Out is an important component of electrical safety and should be trained accordingly.
- Using the proper lighting is another important part of electrical safety. If you can't see what you are doing it's much easier to make a mistake and get hurt.
- Avoid wearing metal jewelry, chains or any other metal objects as they can conduct electricity. All of these objects should be removed before beginning work.
- All equipment should be kept in good working order and free of any debris and grease. This will help with overheating and prevent fires. When cleaning equipment avoid using liquids and metal cleaning equipment as they can conduct electricity.
- Using the proper personal protective equipment is also imperative. Insulated hard hats and gloves can be the difference between life and death.
Work practices are the second category of training that OSHA requires and an integral part of electrical safety training. Make sure that your organization is up-to-date on electrical safety training. It might just save a life.
Charlie Bentson King is a Vice President for Workplace Safety Videos - The world's most comprehensive source of safety video and safety DVD training programs including electrical safety videos. |
OSHA Safety Training Focuses on Safety Management and Risk Reduction in 2011
By Taylor Tremor
As the United States braces itself for yet another series of environmental as well as synthetic catastrophes, the safety-training professionals start to batten down the fences. With the impudence on providing safety training to both employees and subcontractors, on a national front, this posting is on the importance of construction companies to shore up their safety training opportunities.
OSHA Training Courses
Today you will be educated, in a flash, on what one such safety training company, located here in the United States, is doing to open up the Internet and focus on safety management and risk reduction. The safety training game has changed and it is within the context of this alteration that the Internet has granted both speed and fluidity to the design of how construction firms train their workers.
OSHA Construction Training
Safety management is the generalized phrase that defines what a company does to adequately prevent accidents and injuries to the forms workers. Risk reduction can be defined as the actions taken to reduce the amount of risk, either real or perceived, in and on a worksite. What safety training does is serve as a shield against accidents. At the site, safety management as well as risk reduction are the driving factors for superior workplace safety training.
OSHA Construction Training
The OSHA 30 Hour Construction Course thoroughly covers and complies with the requirements set forth by the Occupational Safety and Health Act (OSHA) for all construction-based workers in the United States. As the name implies the course details and explains worker safety and workplace safety protocols in the construction related industry. After passing the final test with a score of 70% or greater, you are then rewarded with the 30 Hour Construction Industry Course Completion Card.
Construction Course Description:
The OSHA 30 Hour Construction Industry Training Course offered will have you up and running, and OSHA compliant in no time! We understand the time constraints and the time spent away from work and family is both limited and precious. That is why we have streamlined the process to make it that much easier for you to be both worker and workplace safety and well on your way to OSHA compliance all in the same setting. You also have the flexibility to monitor your time spent on studying the OSHA 30 Hour Construction Training Safety Course as well as getting ready for the final exam at the end of the course training.
OSHA Training Courses
Today you will be educated, in a flash, on what one such safety training company, located here in the United States, is doing to open up the Internet and focus on safety management and risk reduction. The safety training game has changed and it is within the context of this alteration that the Internet has granted both speed and fluidity to the design of how construction firms train their workers.
OSHA Construction Training
Safety management is the generalized phrase that defines what a company does to adequately prevent accidents and injuries to the forms workers. Risk reduction can be defined as the actions taken to reduce the amount of risk, either real or perceived, in and on a worksite. What safety training does is serve as a shield against accidents. At the site, safety management as well as risk reduction are the driving factors for superior workplace safety training.
OSHA Construction Training
The OSHA 30 Hour Construction Course thoroughly covers and complies with the requirements set forth by the Occupational Safety and Health Act (OSHA) for all construction-based workers in the United States. As the name implies the course details and explains worker safety and workplace safety protocols in the construction related industry. After passing the final test with a score of 70% or greater, you are then rewarded with the 30 Hour Construction Industry Course Completion Card.
Construction Course Description:
The OSHA 30 Hour Construction Industry Training Course offered will have you up and running, and OSHA compliant in no time! We understand the time constraints and the time spent away from work and family is both limited and precious. That is why we have streamlined the process to make it that much easier for you to be both worker and workplace safety and well on your way to OSHA compliance all in the same setting. You also have the flexibility to monitor your time spent on studying the OSHA 30 Hour Construction Training Safety Course as well as getting ready for the final exam at the end of the course training.
Taylor Tremor is a content coordinator for Online OSHA Safety Training. An avid safety and health adviser and professional coordinator, Taylor looks forward to meeting you and fulfilling all of your OSHA compliant training issues at Online OSHA Safety Training! |
The New Red Flags Rule: Preventing Identity Theft
The Red Flags Rule requires many businesses and organizations to implement a written Identity Theft Prevention Program designed to detect the warning signs — or "red flags" — of identity theft in their day-to-day operations.
By identifying red flags in advance, you'll be better equipped to spot suspicious patterns when they arise and take steps to prevent a red flag from escalating into a costly episode of identity theft. Take advantage of other resources on this site to educate your employees and colleagues about complying with the Red Flags Rule.
Help your organization comply with the Red Flags Rule with this new program. This course covers the law's salient points and provides guidelines to meet its stringent requirements. Keep confidential information secure, safeguard your reputation and protect your bottom line with "Red Flags Rule: Preventing Identity Theft".
This powerful program new program teaches employee how to:
- Know the legal definitions of creditor, financial institutions, covered accounts and reasonable foreseeable risk
- Grasp the four steps to Red Flags Rule compliance
- Define and detect the five categories of red flags
- Know how to respond to red flags
OSHA proposal for new Injury and Illness Prevention Program
Injury and Illness Prevention Program
Bryan Seal, of the Directorate of Standards and Guidance, introduced the topic of how the Injury and Illness Prevention Program rule should be organized. OSHA has the task of determining what an Injury and Illness Prevention Program standard would look like; Mr. Seal requested stakeholder input on how the standard should be organized so that covered employers and industries will be able to comply with the rule.
Mr. Seal posed the following questions: OSHA has identified six core elements for inclusion in the standard: (1) management duties; (2) employee participation; (3) hazard identification and assessment; (4) hazard control; (5) education and training; and (6) program evaluation and improvement. Are these core elements an effective foundation for this standard? What should the overall standard look like? What additional tools or appendices would be useful? Do you have successful tools or guidance that can assist employers in compliance with the standard?
Stakeholders provided the following comments and recommendations regarding organization of a rule:
Management Duties
■ Participants stated that management leadership is the key for success for an Injury and Illness Prevention Program —all other components should fall in line if management is committed to an Injury and Illness Prevention Program. As such, stakeholders recommended that the OSHA rule should strongly emphasize the duties required of management.
Employee Participation
■ Numerous participants said that the OSHA standard needs to include elements that ensure employee awareness of, and participation in, an Injury and Illness Prevention Program. Some recommended the standard further allow employees to hold management accountable for Injury and Illness Prevention Program violations.
■ Several stakeholders stated that the OSHA rule should place equal emphasis on the employee involvement and management commitment components. They also recommended that employees should be involved in the planning and decision-making process, because employees have a better understanding of the impact an Injury and Illness Prevention Program will have on workplace hazards.
■ One participant suggested encouraging employee participation using eye-catching posters and other messaging tools. This participant also recommended using diagrams and pictures to overcome language and literacy obstacles.
■ Stakeholders expressed concern that employees might initially be suspicious of an Injury and Illness Prevention Program based on the fear that their input could be used against them. These participants suggested that requesting full involvement from employees, including the writing of an Injury and Illness Prevention Program processes, could convey a more trusting and proactive safety culture, ultimately increasing buy-in from employees.
■ A few participants stated that the OSHA rule should emphasize participation from temporary or contingent employees and day laborers, who are often neglected in an Injury and Illness Prevention Program. These employees must have a mechanism for reporting and controlling workplace hazards.
Hazard Identification and Assessment
■ Many stakeholders indicated that an Injury and Illness Prevention Program is most effective when management, supervisors, and employees collaborate to develop the program. These stakeholders asked that the OSHA rule require collaboration between these constituents.
■ Several stakeholders recommended that the OSHA rule require employers to conduct risk-based hazard assessment surveys. Because not all hazards are equal, the stakeholders stated, OSHA must develop a feasible approach to allow employers to reasonably allocate scarce resources and to address the most significant hazards.
■ Stakeholders stated that the OSHA rule should require written documentation of job hazard analyses and employer responses to identified hazards.
■ Stakeholders urged OSHA to include management of change as a part of hazard identification.
Education and Training
■ Several stakeholders recommended that training be interactive and led by an instructor who can respond to questions or concerns. These stakeholders indicated that requiring employees to watch a training video is significantly less effective at conveying an Injury and Illness Prevention Program.
■ Several participants recommended that the OSHA rule include training for temporary and contingent workers, even if these training requirements are different from the requirements for full-time employees.
■ One participant urged that the rule include training requirements for management personnel. Management personnel are also affected by workplace hazards, the participant said.
■ A stakeholder recommended that hazard identification and control be the first topic addressed in safety training. Employees who understand the hierarchy of risk assessment can safely identify hazards and address them accordingly.
■ Participants stated that employee training should include information on how to report complaints, and should detail the method by which complaints are to be addressed.
■ Several stakeholders said that the OSHA rule should consider literacy levels and language barriers during training.
■ One participant said that Injury and Illness Prevention Program training should follow normal craft training, because employees cannot fully understand hazards unless they understand their job and responsibilities.
■ A few stakeholders mentioned that training should be performance-based, not based on watching a video or attending a class. These stakeholders stated that it is important for employees to understand the training material, rather than merely prove they attended.
Program Evaluation and Improvement
■ Stakeholders stated that the OSHA rule should require written documentation of an Injury and Illness Prevention Program evaluation.
■ Participants suggested that employers should regularly post an evaluation metric of the Injury and Illness Prevention Program, to convey to employees the value of setting an Injury and Illness Prevention Program goal and improving safety.
Additional Elements to Include
■ Stakeholders asked OSHA to include helpful program development tools and guidance documents in the Injury and Illness Prevention Program rule. These stakeholders emphasized that small employers, which lack the resources to hire safety professionals, will need tools to develop an effective Injury and Illness Prevention Program.
■ Participants recommended that OSHA consider literacy levels and language barriers in all components of the rule. These participants stated that the success of an Injury and Illness Prevention Program is largely tied to employees understanding all the applicable elements. A participant suggested that unions can help employers overcome language barriers during the development of an Injury and Illness Prevention Program. Another participant suggested the use of hand-held translators or online translation tools.
■ Stakeholders urged OSHA to promote accountability as an element that is equally important to management responsibility.
■ One participant stated that the OSHA rule should emphasize the accurate reporting of injuries and illnesses.
■ Several stakeholders suggested that the OSHA rule should include voluntary appendices. Voluntary appendices are more easily understood and can serve as a starting point for less-savvy employers, the stakeholders said.
Other Standards and Programs
■ One participant mentioned that the most successful Injury and Illness Prevention Program's in California exist at workplaces with employers who display a strong concern for safety. The participant stated that the safest employees are the ones who know they will not be disciplined for expressing safety concerns. This stakeholder said that many of the employees who have been hurt or died either did not express their concerns about a known hazard or spoke out and were hushed by management.
■ One participant mentioned the Department of Energy's 10 CFR Part 851. This rule includes a model implementation guide and provides suggestions for encouraging employee involvement.
■ A stakeholder stated that Appendix A of the Army Corps of Engineers' 385-1-1 Safety and Health Requirements Manual has guidance on how to prepare an accident prevention plan.
■ One participant mentioned that employers subject to the California state standard have kept inadequate documentation. This participant stated that for a performance-based Injury and Illness Prevention Program rule, clear and thorough documentation is highly important, especially for reference during inspections.
■ A participant stated that the OSHA rule should emphasize the rule's interaction with preexisting standards (e.g., state Injury and Illness Prevention Program standards, industry-specific standards).
■ One stakeholder asked OSHA to include, as an appendix, its publication on job hazard analysis.
■ As part of the HAZWOPER standard, the National Institute of Environmental Health Sciences developed a non-mandatory appendix with minimum criteria for training requirements, a participant said.
1.4 Economic Impact
Bob Burt from the Office of Regulatory Affairs introduced the topic of economic impacts from the Injury and Illness Prevention Program rule. Mr. Burt explained that OSHA is required to demonstrate that its regulations are economically feasible. Additionally, to facilitate OMB's review, OSHA weighs the economic impacts of regulations using the techniques of cost-benefit analyses. Accordingly, OSHA sought stakeholder information about what the potential costs and benefits of an Injury and Illness Prevention Program rule would be.
Mr. Burt posed the following questions to the stakeholders: What are the costs of starting and maintaining an Injury and Illness Prevention Program? What would be the incremental cost to businesses that already have implemented an Injury and Illness Prevention Program? What approaches could be used to minimize costs? What kind of impact would this standard have on small businesses? How can the benefits or the effectiveness of an Injury and Illness Prevention Program be measured? Mr. Burt also asked stakeholders to refer OSHA to any specific sources of cost or benefit data that they were aware of.
Stakeholders provided the following comments and recommendations regarding economic impacts:
Assessing Costs
■ A participant stated that nonprofit organizations have implemented an Injury and Illness Prevention Program in instances where it is not yet required by rule. The participant said that although these organizations must spend resources to develop an Injury and Illness Prevention Program, the reduction in injuries and illnesses has often saved these organizations money. An Injury and Illness Prevention Program has always dropped incident rates, thus lowering compensation costs.
■ A stakeholder with experience in an Injury and Illness Prevention Program said it can take a company 12 months to implement a program if they have a dedicated employee overseeing the effort. If a company does not have a dedicated employee, implementation can take 18 to 24 months, the stakeholder said.
■ One participant suggested that OSHA speak to insurance companies, which might be willing to provide information on potential savings afforded by an Injury and Illness Prevention Program. This participant stated that OSHA should be cautious when obtaining cost data from existing programs, because OSHA's rule might have different Injury and Illness Prevention Program requirements.
Small Businesses
■ A participant suggested that OSHA should consult with small businesses subject to the California state standard. The participant said that these small businesses would be able to speak to the initial costs and maintenance costs that resulted from the state standard.
■ One stakeholder stated that OSHA needs to convince small businesses that an Injury and Illness Prevention Program can be cost effective. One stakeholder stated that small businesses with no injuries will incur costs, but will see no tangible benefit.
Cost-Effectiveness and Costs vs. Benefits
■ One participant recommended that OSHA should strive for a lower-cost standard, even if that reduces the benefits. This participant noted that OSHA cannot address all safety and health issues in a single rule, so it should focus its resources on higher-priority areas.
■ A stakeholder cited an example of an employer that operates in two different countries, one of which requires an Injury and Illness Prevention Program while the other does not. The stakeholder said that in the county that requires an Injury and Illness Prevention Program the company has experienced 37 percent fewer injuries and illnesses.
■ One stakeholder suggested that OSHA consult with employers (e.g., in California) that have longer-running programs in place, because they might have more information on the long-term costs and benefits of an Injury and Illness Prevention Program.
■ In determining the benefits of an Injury and Illness Prevention Program, a stakeholder said that OSHA should be wary of low incident rates, which might be a result of discouraged reporting. This participant said OSHA should also be wary of the benefits afforded by behavior-based safety programs, because these programs do not emphasize the identification of hazards.
■ A participant mentioned that some occupational illnesses (e.g., workplace asthma) are not documented as such, and will not be captured in cost-benefit analyses.
2 Closing Remarks
OSHA representatives thanked the stakeholders for their participation. Ms. Dougherty emphasized that the stakeholder input would greatly help OSHA formulate the standard. She reiterated that the rulemaking is in the early stages and it is difficult to predict the timing of the release of the standard. Mr. Seymour described the procedure for formally submitting comments. Interested parties can provide documents and other information to OSHA. Any information used by OSHA in the preamble will be added to the docket once it is opened.
Bryan Seal, of the Directorate of Standards and Guidance, introduced the topic of how the Injury and Illness Prevention Program rule should be organized. OSHA has the task of determining what an Injury and Illness Prevention Program standard would look like; Mr. Seal requested stakeholder input on how the standard should be organized so that covered employers and industries will be able to comply with the rule.
Mr. Seal posed the following questions: OSHA has identified six core elements for inclusion in the standard: (1) management duties; (2) employee participation; (3) hazard identification and assessment; (4) hazard control; (5) education and training; and (6) program evaluation and improvement. Are these core elements an effective foundation for this standard? What should the overall standard look like? What additional tools or appendices would be useful? Do you have successful tools or guidance that can assist employers in compliance with the standard?
Stakeholders provided the following comments and recommendations regarding organization of a rule:
Management Duties
■ Participants stated that management leadership is the key for success for an Injury and Illness Prevention Program —all other components should fall in line if management is committed to an Injury and Illness Prevention Program. As such, stakeholders recommended that the OSHA rule should strongly emphasize the duties required of management.
Employee Participation
■ Numerous participants said that the OSHA standard needs to include elements that ensure employee awareness of, and participation in, an Injury and Illness Prevention Program. Some recommended the standard further allow employees to hold management accountable for Injury and Illness Prevention Program violations.
■ Several stakeholders stated that the OSHA rule should place equal emphasis on the employee involvement and management commitment components. They also recommended that employees should be involved in the planning and decision-making process, because employees have a better understanding of the impact an Injury and Illness Prevention Program will have on workplace hazards.
■ One participant suggested encouraging employee participation using eye-catching posters and other messaging tools. This participant also recommended using diagrams and pictures to overcome language and literacy obstacles.
■ Stakeholders expressed concern that employees might initially be suspicious of an Injury and Illness Prevention Program based on the fear that their input could be used against them. These participants suggested that requesting full involvement from employees, including the writing of an Injury and Illness Prevention Program processes, could convey a more trusting and proactive safety culture, ultimately increasing buy-in from employees.
■ A few participants stated that the OSHA rule should emphasize participation from temporary or contingent employees and day laborers, who are often neglected in an Injury and Illness Prevention Program. These employees must have a mechanism for reporting and controlling workplace hazards.
Hazard Identification and Assessment
■ Many stakeholders indicated that an Injury and Illness Prevention Program is most effective when management, supervisors, and employees collaborate to develop the program. These stakeholders asked that the OSHA rule require collaboration between these constituents.
■ Several stakeholders recommended that the OSHA rule require employers to conduct risk-based hazard assessment surveys. Because not all hazards are equal, the stakeholders stated, OSHA must develop a feasible approach to allow employers to reasonably allocate scarce resources and to address the most significant hazards.
■ Stakeholders stated that the OSHA rule should require written documentation of job hazard analyses and employer responses to identified hazards.
■ Stakeholders urged OSHA to include management of change as a part of hazard identification.
Education and Training
■ Several stakeholders recommended that training be interactive and led by an instructor who can respond to questions or concerns. These stakeholders indicated that requiring employees to watch a training video is significantly less effective at conveying an Injury and Illness Prevention Program.
■ Several participants recommended that the OSHA rule include training for temporary and contingent workers, even if these training requirements are different from the requirements for full-time employees.
■ One participant urged that the rule include training requirements for management personnel. Management personnel are also affected by workplace hazards, the participant said.
■ A stakeholder recommended that hazard identification and control be the first topic addressed in safety training. Employees who understand the hierarchy of risk assessment can safely identify hazards and address them accordingly.
■ Participants stated that employee training should include information on how to report complaints, and should detail the method by which complaints are to be addressed.
■ Several stakeholders said that the OSHA rule should consider literacy levels and language barriers during training.
■ One participant said that Injury and Illness Prevention Program training should follow normal craft training, because employees cannot fully understand hazards unless they understand their job and responsibilities.
■ A few stakeholders mentioned that training should be performance-based, not based on watching a video or attending a class. These stakeholders stated that it is important for employees to understand the training material, rather than merely prove they attended.
Program Evaluation and Improvement
■ Stakeholders stated that the OSHA rule should require written documentation of an Injury and Illness Prevention Program evaluation.
■ Participants suggested that employers should regularly post an evaluation metric of the Injury and Illness Prevention Program, to convey to employees the value of setting an Injury and Illness Prevention Program goal and improving safety.
Additional Elements to Include
■ Stakeholders asked OSHA to include helpful program development tools and guidance documents in the Injury and Illness Prevention Program rule. These stakeholders emphasized that small employers, which lack the resources to hire safety professionals, will need tools to develop an effective Injury and Illness Prevention Program.
■ Participants recommended that OSHA consider literacy levels and language barriers in all components of the rule. These participants stated that the success of an Injury and Illness Prevention Program is largely tied to employees understanding all the applicable elements. A participant suggested that unions can help employers overcome language barriers during the development of an Injury and Illness Prevention Program. Another participant suggested the use of hand-held translators or online translation tools.
■ Stakeholders urged OSHA to promote accountability as an element that is equally important to management responsibility.
■ One participant stated that the OSHA rule should emphasize the accurate reporting of injuries and illnesses.
■ Several stakeholders suggested that the OSHA rule should include voluntary appendices. Voluntary appendices are more easily understood and can serve as a starting point for less-savvy employers, the stakeholders said.
Other Standards and Programs
■ One participant mentioned that the most successful Injury and Illness Prevention Program's in California exist at workplaces with employers who display a strong concern for safety. The participant stated that the safest employees are the ones who know they will not be disciplined for expressing safety concerns. This stakeholder said that many of the employees who have been hurt or died either did not express their concerns about a known hazard or spoke out and were hushed by management.
■ One participant mentioned the Department of Energy's 10 CFR Part 851. This rule includes a model implementation guide and provides suggestions for encouraging employee involvement.
■ A stakeholder stated that Appendix A of the Army Corps of Engineers' 385-1-1 Safety and Health Requirements Manual has guidance on how to prepare an accident prevention plan.
■ One participant mentioned that employers subject to the California state standard have kept inadequate documentation. This participant stated that for a performance-based Injury and Illness Prevention Program rule, clear and thorough documentation is highly important, especially for reference during inspections.
■ A participant stated that the OSHA rule should emphasize the rule's interaction with preexisting standards (e.g., state Injury and Illness Prevention Program standards, industry-specific standards).
■ One stakeholder asked OSHA to include, as an appendix, its publication on job hazard analysis.
■ As part of the HAZWOPER standard, the National Institute of Environmental Health Sciences developed a non-mandatory appendix with minimum criteria for training requirements, a participant said.
1.4 Economic Impact
Bob Burt from the Office of Regulatory Affairs introduced the topic of economic impacts from the Injury and Illness Prevention Program rule. Mr. Burt explained that OSHA is required to demonstrate that its regulations are economically feasible. Additionally, to facilitate OMB's review, OSHA weighs the economic impacts of regulations using the techniques of cost-benefit analyses. Accordingly, OSHA sought stakeholder information about what the potential costs and benefits of an Injury and Illness Prevention Program rule would be.
Mr. Burt posed the following questions to the stakeholders: What are the costs of starting and maintaining an Injury and Illness Prevention Program? What would be the incremental cost to businesses that already have implemented an Injury and Illness Prevention Program? What approaches could be used to minimize costs? What kind of impact would this standard have on small businesses? How can the benefits or the effectiveness of an Injury and Illness Prevention Program be measured? Mr. Burt also asked stakeholders to refer OSHA to any specific sources of cost or benefit data that they were aware of.
Stakeholders provided the following comments and recommendations regarding economic impacts:
Assessing Costs
■ A participant stated that nonprofit organizations have implemented an Injury and Illness Prevention Program in instances where it is not yet required by rule. The participant said that although these organizations must spend resources to develop an Injury and Illness Prevention Program, the reduction in injuries and illnesses has often saved these organizations money. An Injury and Illness Prevention Program has always dropped incident rates, thus lowering compensation costs.
■ A stakeholder with experience in an Injury and Illness Prevention Program said it can take a company 12 months to implement a program if they have a dedicated employee overseeing the effort. If a company does not have a dedicated employee, implementation can take 18 to 24 months, the stakeholder said.
■ One participant suggested that OSHA speak to insurance companies, which might be willing to provide information on potential savings afforded by an Injury and Illness Prevention Program. This participant stated that OSHA should be cautious when obtaining cost data from existing programs, because OSHA's rule might have different Injury and Illness Prevention Program requirements.
Small Businesses
■ A participant suggested that OSHA should consult with small businesses subject to the California state standard. The participant said that these small businesses would be able to speak to the initial costs and maintenance costs that resulted from the state standard.
■ One stakeholder stated that OSHA needs to convince small businesses that an Injury and Illness Prevention Program can be cost effective. One stakeholder stated that small businesses with no injuries will incur costs, but will see no tangible benefit.
Cost-Effectiveness and Costs vs. Benefits
■ One participant recommended that OSHA should strive for a lower-cost standard, even if that reduces the benefits. This participant noted that OSHA cannot address all safety and health issues in a single rule, so it should focus its resources on higher-priority areas.
■ A stakeholder cited an example of an employer that operates in two different countries, one of which requires an Injury and Illness Prevention Program while the other does not. The stakeholder said that in the county that requires an Injury and Illness Prevention Program the company has experienced 37 percent fewer injuries and illnesses.
■ One stakeholder suggested that OSHA consult with employers (e.g., in California) that have longer-running programs in place, because they might have more information on the long-term costs and benefits of an Injury and Illness Prevention Program.
■ In determining the benefits of an Injury and Illness Prevention Program, a stakeholder said that OSHA should be wary of low incident rates, which might be a result of discouraged reporting. This participant said OSHA should also be wary of the benefits afforded by behavior-based safety programs, because these programs do not emphasize the identification of hazards.
■ A participant mentioned that some occupational illnesses (e.g., workplace asthma) are not documented as such, and will not be captured in cost-benefit analyses.
2 Closing Remarks
OSHA representatives thanked the stakeholders for their participation. Ms. Dougherty emphasized that the stakeholder input would greatly help OSHA formulate the standard. She reiterated that the rulemaking is in the early stages and it is difficult to predict the timing of the release of the standard. Mr. Seymour described the procedure for formally submitting comments. Interested parties can provide documents and other information to OSHA. Any information used by OSHA in the preamble will be added to the docket once it is opened.
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