For a small and underfunded agency, OSHA’s responsibility is huge. In addition to its important role in setting and enforcing standards, OSHA also needs to focus on developing the nation’s safety culture.
How can OSHA help change the safety culture of the nation? Here are some ideas.
Prevention through Design
In the area of “prevention through design” (PtD), OSHA has been reluctant to take initiative, citing its jurisdiction over only employer-employee relationships and noting that designers and architects fit neither category. Yet, moving safety and health “upstream” will better protect both employers and employees. This is a huge opportunity, and OSHA should speak forcefully to designers and architects to accelerate PtD progress.
While OSHA can impose requirements only on employers, owners have ultimate control over construction at their facilities. OSHA should encourage and assist owners to make safety a requirement for the contractors they hire and for all work done under contract. Building from the initiative of owners who already take safety seriously, OSHA can help make this standard industry practice. OSHA can also address other agencies of the federal government which purchase construction services. Without need of rulemaking, the Executive Branch can set an example and ensure that construction safety is a priority and prerequisite on all federally-funded projects.
The NIOSH NORA Construction Sector Council is planning a national campaign to prevent fatalities from falls in construction, but this is the kind of national campaign that should be a core OSHA initiative. A well-targeted, multi-faceted campaign could substantially raise awareness of the problem and build cultural resistance to working at heights without fall protection. Like the use of seatbelts, use of fall protection should be routine. While builders, trade associations, insurance companies and unions all need to be involved in this effort, OSHA should lead the charge. Convening a national conference on safety culture, a campaign in itself, would be step forward.
OSHA has promoted and encouraged worker training for decades, but the focus only on workers has limitations. Workers seldom have the power to make changes to ensure a safe site. That power resides with supervisors who need training as much, if not more, than workers. They need to know how to incorporate safety into project planning, how to communicate with workers about safety and how to encourage workers to speak up about hazardous conditions – in essence, how to create and maintain safety culture on their sites. LIUNA Training and the LHSFNA have had such supervisor safety training for many years. For the greatest impact, OSHA should emphasize supervisor training.
OSHA should identify best practices and actively promote their use through its website. This is particularly important for hazards for which OSHA has no regulations, such as ergonomics. OSHA should have the best ergonomics website in the U.S. with helpful tips that employers can easily find and utilize. Best practices can be rated, much like consumer products on Amazon.com, with feedback from actual users. Many times, simple tips developed in the field are very effective but never shared. At the Latino summit in 2010, one contractor reported he had all his bilingual workers wear a special colored sticker on their hard hat so that non-English speakers instantly know to whom they can go with a question. OSHA should disseminate such practices broadly so more contractors can adopt them. An online “best toolbox talk” contest sponsored by OSHA would generate hundreds of video uploads and give employers a real vision for how an effective toolbox talk can be run.
In an era of limited budgets and assaults on regulations, OSHA must become more strategic and creative in fulfilling its mission. This is how to realize the dream, 40 years ago, of a safe workplace for all Americans.
[Scott Schneider is the LHSFNA’s Occupational Safety and Health Division Director.]