Too many organizations fool themselves and think complying
with the OSHA requirements actually means that they have a good safety program
and culture. The truth is, that they are actually poised to fail. Remember that
these requirements are minimum standards so by adhering to them you have left
little room for error. The best example I can provide to illustrate the
potential for failure is employee exposure scenarios. OSHA publishes many
exposure levels most are equated with a permissible exposure limit (PEL) 8-hour
time weight average. You should remember that PELs are not absolutes but what most people can be exposed to without
adverse health effects. So for some workers, adverse health effects may occur.
Additionally, many of the PELs are outdated. This being said, I’m not
advocating becoming risk adverse.
We are exposed to risk in almost everything we do. For an
organization to have a progressive safety culture they need to evaluate those
risk and where possible eliminate what you can. Where you are unable to
eliminate the hazards then a mitigation strategy must be applied. This strategy
should follow the hierarchy of controls employing engineering controls first followed
by administrative controls and work practices the lastly the use of Personnel
Protective Equipment (PPE). The key is
to evaluate your work processes and seek out activities where following the
minimum requirements could have adverse effects if sliding off that minimum
edge occurs.
“Don't lower your expectations to meet your performance. Raise your level of performance to meet your expectations.” Ralph Marston