Does your organization have a routine safety manual review process? How long has it been since you last read your organization’s safety manuals?
For safety professionals, I hope the answer is at least, “Within the past year”. For all other employees, I hope the answer isn’t, “What manuals?”
The Importance of Safety Manual Review
Well-written safety manuals are a critical, but often underappreciated component of a strong safety program. High-quality manuals define official policies, clarify regulations, and guide safe practices. But only when they’re maintained.
Why is routine review important?
Safety programs aren’t static. To remain effective, safety manuals need to be regularly updated to reflect changing workplace hazards and processes. Because following internal policies and procedures is as important as regulatory compliance, out-of-date manuals can represent a significant liability.
Things to consider:
- Safety manuals serve a larger purpose than simply fulfilling a regulatory requirement. Well-maintained manuals guide safe work practices and serve as a basis for defining safe and compliant behavior. The policy language documented in the safety manuals can serve as a reference point for mitigating conflicts when employees fail to comply with company policy.
- Regulators often review safety manuals during inspections and post-incident audits. Safety manuals define the organization’s internal safety regulations, and these policies effectively serve as the compliance baseline for the program. This is true even when internal commitments exceed regulatory requirements. Following serious incidents, regulators often request internal safety policies, training materials, and manuals and inconsistencies can be cited in the final report.
- Clarity is important. When developing policies, keep in mind that generic language can be overly restrictive in certain contexts. For example, consider a common policy statement like, “Faceshield use is required when working with corrosives.” This may sound well-intentioned, but it requires all employees to wear a faceshield when working with any corrosive material, regardless of concentration or volume. Depending on the range of uses in your facility (think dilute bleach or other corrosive cleaners), the policy language may need further clarification.
- Follow through is critical. Always be sure to verify your commitments. For example, a policy like, “Spill kits are located under every sink”, ensures employees will be able to quickly and easily locate spill kit supplies in the event of an emergency (but only if the policy is followed). When manuals commit to specific policies, there needs to be a system for confirming internal compliance. In this case, a simple monthly check to verify spill kit supplies would be a great solution.
How to Improve the Review Process
How do you ensure manuals are up-to-date and specific?
Familiarize yourself with your manuals.
It may sound simple, but I often find that safety team members aren’t as familiar with the content of their manuals as they should be. If you’re new to a program, always conducted a thorough review of the existing manuals to make sure they’re properly customized. Organizations are ultimately responsible for all policy language, even when developed by a consultant.
Review your manuals at least annually.
Many regulations, including the OSHA Bloodborne Pathogen and Lab Standards, require annual safety manual review. However, this should serve as the minimum review period, not the default. While conducting reviews make sure to update all components and focus on specific policy language. It’s not enough to simply update regulatory citations and personnel contact information. Including a revision history and signature page to formally document reviews and revisions is also a great practice.
Consider requiring all employees to read the safety manuals upon hire.
For some safety programs, this may already be standard practice, but it’s certainly not universal. Many regulations require manuals to be readily available and for initial training to adequately cover the relevant material, but formal, documented manual reviews are not required. That said, having all employees review your manuals can increase compliance and provide a higher level of quality control.
If you have any questions about your annual safety manual review process, feel free to contact us at email@example.com or spotlightsafetyinc.com to schedule a free consultation and information session.