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OSHA Issues New Guidelines for Safety and Health Programs

By Bradford T. Hammock
  • November 9, 2016

In its first comprehensive changes in 30 years, the Occupational Safety and Health Administration has updated its Guidelines for Safety and Health Programs to reflect “changes in the economy, workplaces, and evolving safety and health issues.”

Assistant Secretary of Labor for Occupational Safety and Health David Michaels released “Recommended Practices for Safety and Health Programs” at the National Safety Council Congress public education campaign, “A safe workplace is sound business,” on October 18. The agency said the recommendations are advisory and do not represent new legal obligations or alter existing obligations created by OSHA standards or regulations.

The OSHA official said:

Since OSHA’s original guidelines were published more than 25 years ago, employers and employees have gained a lot of experience in how to use safety and health programs to systematically prevent injuries and illnesses in the workplace. We know that working together to implement these programs will help prevent injuries and illnesses, and also make businesses more sustainable.

OSHA said the changes to its 1989 Safety and Health Program Management Guidelines are designed to prevent workplace injuries, illnesses and deaths, as well as “suffering and financial hardship” on workers, their families and employers, rather than being “reactive,” following an injury, illness or death, or an outside inspection.

The initiative includes a “Safety and Health Program Audit Tool” covering the seven key sections of the new OSHA guidelines:

  1. Management leadership;
  2. Worker participation;
  3. Hazard identification and assessment;
  4. Hazard prevention and control;
  5. Education and training;
  6. Program evaluation and improvement; and
  7. Communication and coordination for host employers, contractors, and staffing agencies.

OSHA said the recommendations reflect changes in the workplace over the past three decades, such as a shift from a manufacturing to service base and from a “fixed” to an increasingly mobile workforce. In addition, OSHA said the automation of work activities has meant the growing role of technology, computers, and robotics has meant “new and different hazards.”

Further, increased diversity in the workplace has meant more cross-cultural interactions, including the use of different languages, according to OSHA. An aging workforce and the rise of sedentary work and lifestyle have meant some workers are at higher risk for work-related musculoskeletal disorders. Workers in industries typically considered safe, including healthcare, lodging, retail, and transportation, face “significant” hazards, OSHA said.

Increased temporary and contract employment, as well as the increase of the “gig economy,” the federal safety agency said, means that traditional relationships between workers and employers are changing, and safety programs and policies must make certain the safety of all workers in “newer and more fluid relationships.”

Jackson Lewis is available to assist with understanding the new OSHA guidelines.

©2016 Jackson Lewis P.C. This Update is provided for informational purposes only. It is not intended as legal advice nor does it create an attorney/client relationship between Jackson Lewis and any readers or recipients. Readers should consult counsel of their own choosing to discuss how these matters relate to their individual circumstances. Reproduction in whole or in part is prohibited without the express written consent of Jackson Lewis.

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