Let’s Meet – And Talk – About Shop Safety
by Carol Keyes, CSP, CCM, CRC
You meet with your staff. Maybe it’s daily, to discuss production schedules. Maybe it’s weekly, to check in and see how things are going. Maybe safety concerns are brought up – is that hoist not working right? Is that outlet dead? These are usually informal meetings, with no record of who attended and not much done to track what was discussed.
Those shop meetings are useful, but safety is likely taking a back seat. There’s a way to bring it forward – establish a safety committee.
Do you need to have a safety committee? Probably. If you have more than 25 employees, you do. If you’re required to have an AWAIR program (a basic safety program, outlining responsibilities), you do. Whether you need an AWAIR program is based on your industry’s injury rate. That list is updated every five years. And that list currently includes any automotive repair shop (mechanical, collision, glass replacement, oil change, car washes…).
So if you work on cars, regardless of how small you are, you need a safety committee. (An aside: if you have 10 or fewer employees, OSHA’s not likely to do a planned safety inspection, the most common type. While a small shop must have a safety committee, it probably would not face an OSHA penalty for lack of a committee).
Who needs to be on the committee? It must be at least half employees, and the employees should select who’s on the committee. If you have a union, the union chooses members.
What should a safety committee do?
Minnesota rules spell out some requirements. If you have a bad injury record, at least 1.4 times your industry average, the safety committee must do a walkaround of your shop at least once each quarter, looking for any hazards. You need to keep a record of those hazards and what the committee recommended to correct the hazard. The committee needs to have a way to solicit safety suggestions and hazard reports. It is supposed to review any work-related injuries or illnesses and come up with recommendations to prevent recurrences. You need to keep a record of those recommendations for at least two years.
Just one more bureaucratic layer, right? Change your thinking – a safety committee doesn’t have to be too onerous, and it can make your shop safer. You’re allowed a lot of flexibility in how you structure and run the committee. Other than the quarterly meeting requirement for high-injury shops, the rules don’t say how often you need to meet. The rules don’t dictate how big the committee has to be or exactly what the committee has to do. The most important point: employees need to know they have an avenue to raise safety concerns.
If you have a shop with a dozen employees, how could you structure the safety committee? You might consider having a committee of the whole – have all employees be part of the committee.
Or encourage a few employees to volunteer to participate. While safety committee members are supposed to be chosen by their peers, our experience has been that people don’t tend to step forward without encouragement. By the way, you need to pay employees for their work on the safety committee.
At least once or (better yet) twice a year, gather everyone together. Make it clear the purpose is to discuss any safety concerns and the past year’s or past six months’ safety performance. What injuries occurred? Does anyone have ideas to prevent them? Were there any safety incidents – where equipment was damaged or where somebody said, “whew, that was a close one?”
You could make this part of your shop meeting, but make sure the safety part is documented.
You can meet more often than once or twice a year – you decide. For larger shops, meeting quarterly may make more sense. Bring in lunch for the committee members, as everyone participates better with food.
Keep a record of who was there and what was discussed. It can be handwritten, but make sure it includes the date and any follow-up actions required. Post that record on the employee bulletin board.
Once a year, have your safety committee develop some goals – not “have no accidents” but things people can do, such as check the vehicle hoists, get all containers labeled or ask your local fire department if they will train your employees on fire extinguisher use.
Enlist safety committee members to check the things that require routine inspections. Fire extinguishers need to be looked at each month, to make sure they are where they’re supposed to be and are still charged. Plumbed eyewashes need to be flushed each week, so they don’t develop crud in the lines. Gravity fed eyewashes need to be checked to ensure the solution hasn’t expired or been used. Exit lights don’t do any good if the batteries are dead and they don’t light up. Assign the tasks of checking these to safety committee members.
We send our clients monthly building inspection forms. Develop your own. Then delegate completing it to safety committee members. Rotate the task, so different people start learning to look for safety hazards – and so it isn’t much of a burden for any one person.
When OSHA does an inspection, the inspector will ask if you have a safety committee. The inspector will also ask that question of employees. If the answer is no, you’ll not only be cited for lack of a committee, but you’ll pay more for any other violations found. OSHA discounts penalties based on company size, history and good faith. If you don’t have a safety committee, you won’t get the full good faith discount. That could be the difference between getting a $250 citation and a $1,000 citation. Not a huge amount itself, but these can add up.
Put together a safety committee. Meet routinely – every January, if you decide on once-a-year meetings. Take the opportunity to review last year’s safety performance – what injuries occurred? What accidents happened? Ask if there are any safety concerns. Document.
That’s not so difficult, now, is it?
For more information, contact Carol Keyes at carkey@chess-safety.com or 651-842-9210.
Want more? Check out the October 2024 issue of AASP-MN News!