David P. Gilkey, DC, PhD, CPE, DACBOH
The occupational health and safety (OHS) program is the foundation for achieving a healthy workplace. It establishes the framework to which is attached individual health and safety programs like ergonomics, back injury prevention, worker fitness, wellness, chemical safety, etc. Effective OHS programs have some common basic elements: management and employee commitment, hazard identification, hazard control, and training for workers (OSHA, 1992). Each OHS program is designed to meet the needs of each individual company, their workers, management, work process, and environment. Chiropractic OHS physicians can assist employers in developing their special programs to protect workers and reduce work related injury and illness.
The newest trend in workplace safety and health has been to incorporate all areas that affect human health for both workers and nonworkers into one unit, the environmental, health, and safety (EHS) department. This department of professionals not only strives to protect the immediate health and safety of the workers, but protects the environment and public as well. Comprehensive EHS programs ensure compliance with environmental laws that protect those who might be affected by hazardous contamination of the soil, water, air, or waste materials. EHS also ensures compliance with the health and safety laws promulgated by federal and state OSHA, state and local health departments, and other jurisdictional authorities.
Basic EHS programs include the following key elements (Gilkey, 1993; Cal/OSHA, 1991):
- Written Program -- It is important to have a written program document, binder, or computer file. This allows the company to clearly state their commitment to good EHS practices, and enables all employees to read, study, and understand their responsibilities as it relates to company EHS practices, procedures, and policies. It must also identify company representative who has authority and is responsible for the EHS program.
- Employee Compliance -- There must be defined methods of compliance compelling employees to adhere to the company safe work practices. If employees do not comply they will face progressive enforcement action: verbal reprimand, write-ups, suspension, or even dismissal. The serious nature of the company commitment to health and safety of the workplace and the public must be conveyed.
- Employee Communication -- There must be a means of communication by workers without retribution. The employer must be prepared to receive complaints of unsafe practices or suggestions to improve the workplace from employees.
- Hazard Identification - There must be planned inspections of the workplace to identify workplace hazards. Inspections should be at regular periodic intervals, when accidents occur, and when a new hazard is suspected or recognized.
- Accident Investigation -- Accident investigation is an integral part of injury prevention planning and improvement. Information about prior accidents can form the basis for developing, evolving, and improving safe work practices.
- Corrective Action -- There must be methods available to eliminate or reduce hazards identified in the workplace. Corrective actions are methods such as: administrative, engineering, personal protection equipment, or training that eliminate or reduce the chance of injury or illness from workplace exposures.
- Worker Training -- Proper training provides clear and understandable communication on safe daily work practices, employee responsibility, emergency procedures, and reporting requirements. It must also be completed at regular periodic intervals, when an employee begins a new job; when a training deficiency is recognized; when a new hazard is identified or brought into the workplace. Training is key to safe worker behaviors.
- Record Keeping -- Documentation is required by law for many aspects of EHS. Records generation and retention are often fundamental proof that EHS procedures were followed. Well organized records can be used to trigger protocols for accident investigation, training, reporting, and auditing.
The final determination of the total EHS program content is only accomplished through an assessment of needs. The chiropractic OHS physician must visit the worksite and identify all work processes, environment, personnel, and facilities, determine the level of management commitment, and applicable laws. In some cases the company might not be aware of their responsibility to certain EHS regulations, laws, and requirements; in those cases it becomes necessary to inform and educate. A comprehensive EHS program includes the basic eight elements above, but may also address other potential issues of concern (Friedman, 1993; Gilkey & Williams, 1994):
- procedures for complying with notification requirements to proper EHS authorities;
- procedures for responding to cleanup incidents;
- effective utilization of outside consultants or counsel;
- a policy on independent assessment and audit for all EHS programs;
- a waste minimization program;
- a product risk evaluation process;
- a policy on the right to defense and continued employment;
- a policy on full disclosure of EHS matters;
- a policy for protection of employees who make information available to the public;
- a policy and program for communicating with regulators and the public;
- an independent environmental advocate on the board of directors and a vice president for environmental affairs.
Additional Specific EHS Programs - emergency and evacuation
- fire protection
- earthquake
- fleet safety
- medical management
- workers' compensation
- back injury prevention
- ergonomics
- bloodborne pathogen protection
- hazard communication and chemical hygiene
EHS Support Programs and Committees - Safety Committee
- Product Safety Committee
- Community Relations Committee
- Media Relations Committee
- Regulatory Agency Relations Committee
When the foundation for safe work practices are firmly laid in a quality EHS program, then allocation of valuable resources can be shifted to the implementation and operation of the program. The chiropractic EHS physician can also play an integral part in implementation by guiding company representatives in the necessary steps to see their program to fruition. A program supported by management and labor becomes part of the company culture and everyone ultimately benefits. The program is like a flight plan that guides the pilot to the destination, it's of paramount importance!
References
Cal/OSHA. (1991). Guide to Developing Your Workplace Injury and Illness Prevention Program. State of California, Department of Industrial Relations, Division of Occupational Safety and Health. San Francisco, CA: Cal/OSHA.
Friedman FB (1993). Practical Guide to Environmental Management. Washington, D.C.: Environmental Law Institute.
Gilkey DP (1993). Health and safety in the workplace: developing a basic plan. California Chiropractic Association Journal, 10, 36-37.
Gilkey DP, Williams HA (1994). The comprehensive environmental, health, and safety program: A new trend in industry. Journal of Chiropractic, 8, 22-26.
OSHA. (1992). OSHA Handbook for Small Businesses. Washington, D.C.: U.S. Department of Labor.
David Gilkey, DC, DABCO, DACBOH, FICC Past President, Council on Occupational Health/ACA Secretary, American Chiropractic Board of Occupational Health/ACA
