Creating a strong safety culture in a business has many components. It requires the commitment and participation of the executive management team and all supervisory and non-supervisory employees throughout the organization. A critical part of accomplishing this requires conducting internal and/or third-party safety and health audits on a routine basis and whenever business needs otherwise dictate, e.g., after an injury or a near-miss incident. There are many benefits to having regular health and safety audits at your business, including increasing efficiency, avoiding legal risks, ensuring compliance with federal and state regulations, helping to keep insurance premiums low, and keeping workers out of danger. Doing so is also a clear sign to employees that the business is prepared to dedicate resources and time to ensure their safety and health is not just a lip service type issue. OSHA generally recommends that all employers conduct regular safety audits at least once a year and, in some situations, may impose fines on companies that fail to have them as a regulatory compliance matter.
Safety and health audits can be done internally, but there may be compelling reasons that a business may want them done by a third-party independent safety and health consultant. The issue of who should conduct safety and health audits is fact sensitive and may turn on various factors such as available resources and timing. In addition, companies should carefully consider other issues, such as whether the audit may be covered under the attorney-client privilege.
In some situations, businesses might use OSHA’s free on-site consultation program. OSHA’s on-site consultation program is a great opportunity, particularly for smaller businesses or those without in-house safety and health expertise, to improve their health and safety programs at no cost using experienced safety and health consultants. The program aims to help employers identify and address hazards to protect their workers and ensure that their workplace safety programs are working as intended. Consultation is generally conducted through three basic steps:
- The company submits a request for a free consultation.
- An assigned safety and/or health consultant will work with the business to discuss concerns and identify ways to improve safety and health at the workplace.
- The consultant will request the employer commit to correcting serious safety hazards and implement other appropriate recommendations to ensure the safety of employees and avoid risk and liability.
These consultations are confidential and separate from OSHA enforcement efforts, so the consultants do not “report” potential violations to OSHA enforcement staff. Additional information on OSHA’s consultation program is available here. To book a consultation, you may visit here.
The author is grateful for the contribution of summer intern Katherine Carlson in the preparation of this article.