Six Tips for Creating Cohesive Policies: The Key to a Solid Safety Program

One of the first concerns clients express to Trapane Group, LLC is, “How do we improve the cohesiveness of our safety program?”  to which I reply, “Let’s first look at your policies.”  Policies are the cornerstone of any safety program.  There is an old adage that says, “If it’s not written down, it didn’t happen.” Policies are to organizations what Google directions are to drivers on unfamiliar roads. Regulators look at your policies first when they visit your organization.  This helps them understand company culture, how programs are implemented and what to look for when they tour your facilities.  The following bullet points will help you solidify your safety program, feel confident about visit from regulators and will help with overall compliance.

• Outline your practices – in other words, your policies should “say what you do” and your staff should “do what they say”.  One of the easiest ways for regulators to pass out violations is to read your policies and find contradictions between them and employee practices.  
• Include local laws and regulations – Most organizations include major regulatory requirements, i.e. OSHA, TJC, EPA, but are not aware of the requirements from the AHJ (Authority Having Jurisdiction).  For example, in San Diego, California OSHA regulations are required but in the city of San Diego, the San Diego Fire Department and San Diego County Hazardous Materials Division are the AHJs when it comes to fire safety and hazardous materials and waste programs.  This is not to say other agency requirements should not be included because they MUST be, but there is a discernment that must occur to understand the differences and to know how to comply. For help with this, consider using a consultant.    
• Review and Update Often – Most policies should be reviewed annually.  This may be not be a regulatory requirement but reviewing them annually will improve a few things:
  • There will be less likelihood of missing important regulatory changes to include in policy updates.
  • Leaders will be better equipped to communicate policy details and identify when they are not being followed or if a process improvement should be made.
  • Reviewing policies tends to initiate conversations about strategy, direction, and purpose, which, in turn, elevates the organization’s safety culture and overall program.  
• For multi-state or multi-facility organizations, spend time on learning how to develop and maintain your policies – There are many ways to organize and maintain policies and taking time to develop a strategy around this is especially important if you do business in states that have state OSHA programs and other applicable regulations, like California.  (Keep in mind there are 21 states that currently have State OSHA programs; and Puerto Rico.) The organization’s headquarters may be responsible for knowing the differences in regulations and writing the policies accordingly.  This can be close to impossible without knowing the differences or knowing the specifics of the safety program in that state.  (For Healthcare, here is an informative article written for the Center for Improvement in Healthcare Quality, CIHQ regarding this topic.)
• Train, Train, Then Train Some More – Most organizations train according to regulatory requirement.  Consider that there are many ways to train without taking time away from productivity.  Training can be built into everyday events such as morning rounds, bulletin boards in prominent places, newsletters, company meetings, and weekly employee meetings.  Whenever employees gather for a professional purpose, train! If you do it often, you can break up topics or policy changes into smaller pieces.  One of my favorite training exercises is to create a topical calendar and focus employees’ attention on a different safety topic monthly.  To learn more, click here. 
• Link Related Documents – Many organizations do this to some extent but not completely; consider relating documents that a) meet the regulatory requirements of the main policy and b) help your organization prove compliance by showing related documents that lay out the HOWs of your processes.  If there are regulations you’d like to link, consider making a new section in your policy called Applicable Regulations or Regulatory Links.  

There are a lot of informative articles about policy development and management.  Here is one from Sweet Process. It may also be invaluable to your organization to hire a consultant, i.e. “fresh eyes” to dig in and perform a gap analysis that will help put any potential issues in order of priority.  Following these tips can help any organization gain control over the daunting tasks related to policy development and management.  Good luck and remember you don’t have to have all the answers. You just have to know who to call to get them!