I'm from the government and I'm here to help you
Those words have often struck terror into the hearts of station management. This also applies to visits by representatives of the Occupational Safety and Health Administration (OSHA). It has been said that the acronym for that organization comes from the first comment made by the chief engineer when he hears that they are on site — “Oh Sha!” or something like that — which may be just a rumor. In any case, the worry accompanying their arrival may be unfounded as they really can be a valuable asset to the staff in improving conditions in the workspaces.
Everyone should be aware by now of the existence of OSHA and their role in investigating accidents. That awareness also should extend to knowing of the requirement for a climbing safety device on all new towers. Many are still unaware of the assistance offered by OSHA to help stations avoid violations and improve overall working safety conditions.
A quick visit to the Web site www.osha.gov can be of great help. There you will find compliance guides and directives as well as the agency library. You can also find the complete OSHA regulations, although they are a bit bulky to attempt to browse. A better solution is to find the address of the area office of that agency. Then plan a visit to that office the next time you are in its vicinity. At the same time you can schedule a meeting with a representative to discuss your operation and how the OSHA regulations may apply.
It is also possible to schedule a visit from an OSHA representative to your station to review your operations and safety practices. They will gladly (or at least cordially) make such a visit and give you guidance in meeting their requirements. This is a no-cost trip that can save you very big bucks if someone is injured in an accident while at work. It is highly recommended.
At the least, the regulations require that stations perform a hazard assessment of their facility to determine those factors or conditions that may be dangerous for your staff. That assessment should be posted at the station and signed by all your staff after they have read it and discussed it with the chief engineer. In addition, safety meetings for the staff are necessary periodically to discuss hazards and work that is being performed. Those meetings are essential when construction is being performed on the site. In addition, there are actions that must be taken during construction such as the mandatory wearing of hard hats, warning sign placement, notifications of measures to be taken if accidents occur, etc.
If an accident does occur at the station where someone is injured, OSHA should be advised immediately in case they want to investigate the occurrence. It is much better for the station to advise them of the accident than for them to find out from the news media or through a complaint from a staff member. The first rule in such an incident is to bare the corporate soul in total. In other words, be honest with them as to what happened, why it happened and what may have been done incorrectly. They will find out anyway and having it freely and completely disclosed will indicate your willingness to cooperate with their investigation. In addition to notifying OSHA when an accident occurs, immediately start a log of times and actions taken concerning the incident. It should show dates and times for all actions, who was advised and who took action, what conditions existed at the time of the accident, and as much detail as possible to clarify the situation. Document everything clearly and honestly. If it is determined that someone lied to the investigator, every stone will be turned and examined in detail based on the fact that some type of cover-up may be taking place.
Let it be assumed that the accident was just that — an accident that involved something that could not or wasn't anticipated and that involved, at worst, an honest mistake by someone. OSHA isn't going to come in and slap hundreds of thousands of dollars in fines on everyone if reasonable precautions were taken. If they find that the station did something wrong or not in accordance with their regulations, a fine may result, but it probably won't be major. This is especially true if the required safety meetings and precautions were taken. The really big fines occur if a hazardous condition existed that was known to the management but concealed from the actual workers who were directed to perform the work anyway. Those events may result in major penalties, as they should.
A big service that OSHA will provide if an accident occurs is to help the station determine changes that can be made to avoid the recurrence of the incident. They will help the station better determine existing or possible hazards, notify the staff of such conditions, and make changes to improve overall safety.
If OSHA makes suggestions concerning changes to be made, take action promptly on such suggestions. If their recommendations are ignored or if promised changes by the station are not completed and another accident results, woe unto all involved. Not only will the resulting fines be considerably larger, the station has just opened the door for all sorts of civil damage actions by the workers involved.
Much like FCC regulations, OSHA regulations may be something that the station would rather not deal with. However, all are simply a condition of doing business. Your staff should be fully aware of those occasions that require systems to be disabled during work by “lock-out, tag-out” procedures, how such actions are to be taken and just who bears the responsibility for taking such actions. The procedures for dealing with accidents should be known by all staff members and acknowledged by signing the appropriate documents that, in turn, should be properly posted.
Use the OSHA requirements to prepare a training manual for all new hires at the station. Again, the use of a training manual along with a signing sheet to show that appropriate training has occurred is not only an attempt to meet the applicable regulations, it is simply good business practice. Working to comply with OSHA regulations before someone is hurt on the job is good operating practice, good business and a great action to cover your stern sections from resultant serious damage.
Don Markley is president of D.L. Markley and Associates, Peoria, IL.
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