Regulatory Compliance

WPA art project, Artist Allan Nase 1937

WPA art project, Artist Allan Nase 1937

Regulations regarding safety must be viewed as a baseline and not the endpoint of an industrial safety program.

As most OSHA regulations are aimed at preventing catastrophes, they leave enormous areas of industrial practice unregulated or at best minimally controlled. In addition, OSHA law represents what can get passed through the U.S. Congress and not necessarily what would be viewed as best practice. For example, OSHA has set limits of exposures for certain chemicals. This list often does not represent the latest research in the field and is rarely updated as that requires action by Congress. A better alternative is to use the ACGIH (American Conference of Governmental Industrial Hygienists) guidelines.  These are updated every year using research and a vetting process that tries to assure that it is kept current and relevant.

Other regulations that are part of OSHA requirements are those that are referred to as consensus standards. Instead of crafting its own regulations which can lead to conflicting requirements, OSHA sometimes simply refers to an appropriate consensus standard from the NFPA, NEC, CGA, ANSI and others.

Basic compliance must be a given for any legitimate safety program. Training to the standard, using appropriate implementation strategies and methodical data driven follow up are included in my regulatory training. It is not enough to do it – it must be done well. Doing it well means that the employee is clear about what is expected and understands the value of compliance.

For Management to rest easy, it is essential that periodic measurements using a set of standard criteria be performed to test compliance. If these measurements are not made, then assumptions about the shop floor reality are made – and we all know assumptions are dangerous.