OSHA Regulations Are Minimum Standards Not Gold Standards

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 Additionally, many of the PELs are outdated.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