Guide to Safety and Health Policies, Procedures, and Model Programs

Introduction

The purpose of the SMACNA Guide to Safety and Health Policies, Procedures and Model Programs product is to provide contractors in the sheet metal and HVAC industry with a written safety and health program in Microsoft Word® and Powerpoint® format so they are fully editable. However, you will need to “save” the document or file to a computer “C” drive, computer network server, or other file storage device. This program includes model policies, procedures, written programs, checklists, and PowerPoint presentations that can be modified to fit the needs of individual contractors.

General Instructions

The information contained in this program can be edited to meet the user’s needs. Most written programs require the user to insert the Company name in the beginning of the program. Thereby, references throughout the program to “the Company” will be to the individual user’s company.

The user is encouraged to review each program for company-specific needs and requirements, and edit the information accordingly. The programs generally contain basic information in order that they fit most applications with limited editing. However, users are cautioned to ensure that the information is proper for the required application. The first step is to ensure that Company owners and management agree with and support all the information presented in the program.

Disclaimer

The Sheet Metal and Air Conditioning Contractors’ National Association, Inc. (SMACNA) provide no guarantees or warranties, either express or implied with respect to the accuracy and sufficiency of the data published in the SMACNA Guide to Safety and Health Policies, Procedures, and Model Programs CD product or associated web pages.

In particular SMACNA disclaims any implied warranty of merchantability or fitness for particular purpose. SMACNA hereby disclaims all responsibility and liability for any loss or damage that may arise from the use of the data or methods used in this program. Under no circumstances shall SMACNA be liable for incidental or consequential damages.

The data and information contained in this program are for illustration and training purposes only.  Your use of any of this data and information is at your own risk, and you should not use any of these sample documents without first seeking legal and other professional advice.  The provision of this data and information does not constitute legal advice or opinions of any kind. No lawyer-client, advisory, fiduciary or other relationship is created between SMACNA and any person accessing or otherwise using any the data or information.  Users of this data and information should verify data and information for each individual application to allow for the differing conditions of each shop, jobsite, project or segment of each project and use their own management expertise to develop the appropriate procedures for their own use. SMACNA make no warranty regarding the results of use of the product. The following specific section instructions provide information on each section of the guide. Users are advised to read over the material and make appropriate revisions to meet the needs of each company. Although specific to a topic, the information may differ from current company policies and procedures, as well as local and state regulatory agencies. Revisions should be made accordingly.

Part I: Policies

Section I: Safety and Health Policy Statement

• Special attention needs to be on approving the mandatory policies including the disciplinary policy, as presented. If not approved as written, they should be modified accordingly.
• This policy introduces a “Safety Manager”. Users are encouraged to have a key management position named as the Safety Manager. This person will have significant responsibilities within these polices and procedures. You may wish to replace this title with an existing safety representative title for your company such as Safety Director or Vice President of Safety. This person should have adequate skills, knowledge, and competencies to implement the safety and health policies and procedures as required.
• Users are encouraged to review a copy of the Construction Owners Safety Blueprint©, prepared by The Construction Users Roundtable (CURT). That document contains additional helpful information on safety and health programs.
• Signature of the highest ranking Company representative (President, CEO, etc.) is important, in that it shows a high level of commitment to the safety and health program.

Section II: OSHA Inspection Policy

• The important issue with this section is that the user does sufficient pre-planning to prepare for an OSHA inspection. The information provided is a policy but users should ensure that all levels of management and supervision are familiar with OSHA policies and standards.
• It should be noted that about one-half of the states have state-supported OSHA programs (e.g., California, Washington, Virginia, Minnesota, and Maryland) and that those standards may be more stringent than Federal OSHA.
• More information on OSHA (and state plan OSHA programs) can be found at the Federal OSHA website.

Section III: Injury, Illness, and Accident Policy

• This section is the policy to promote attention to properly dealing with injuries, illnesses and property damage accidents. Users are encouraged to review and apply the information in Section IX, Reporting and Investigating On-The-Job Accidents, Injuries and Illnesses.

Section IV: Recordkeeping Policy

• The key issue with this section is to ensure that the Company is aware of the applicable recordkeeping requirements established by OSHA.
• The user should understand that “recording” injuries and illnesses is different from “reporting”, in that, recording means maintaining a log of injuries and illnesses when they occur. Reporting means that the Company contact OSHA (or state program) when a fatality or multiple injury incident occurs.
• Additional information on Recordkeeping can be found on the OSHA website. Also, SMACNA offers a free on-line Recordkeeping Course available through the Safety webpage of the SMACNA website, or by contacting the SMACNA Safety Department at 703-803-2980.

Section V: Code of Safety Practices

• This section is a general list of safety practices that apply to most work environments. The Company is encouraged to read over these safety practices and revise according to company priorities and business culture.

Section VI: Safety Committee Policy

• This section is a policy to promote implementation of a company safety committee. The user needs to make an informed, deliberate decision prior to implementing a safety committee. That is, one main issue found to contribute to failure of safety committees is the inability of the Company to respond to the recommendations and suggestions provided by the committee.

Part II: Procedures

Section VII: Employee Training And Communications Procedure

• This section provides guidance on how to effectively prioritize and implement a safety and health training program. Companies are encouraged not to ignore training on the health issues such as hearing loss, musculoskeletal disorders, and chemical over-exposures.
• SMACNA contractors should be aware that the SMACNA Safety Department can provide various training resources including manuals and related products produced by SMACNA; and CDs and DVDs produced by the Sheet Metal Occupational Health Institute Trust (SMOHIT).

Section VIII: Workplace Inspections And Job Hazard Assessments Procedure

• This section encourages a proactive approach to identifying safety and health hazards before they become an injury or illness event.

Section IX: Reporting And Investigating On-The-Job Accidents, Injuries And Illnesses Procedure

• This section describes steps to take after an accident occurs. This is an important step in the safety program process as it helps to mitigate and lessen loses that result from injuries and illnesses. Accident investigation is important to learning how to improve a safety and health program.

Section X: OSHA Inspection Procedure

• This section provides a summary of the steps involved in handling an OSHA inspection. Companies are encouraged to train management and supervisors how to be prepared for a regulatory inspection.

Part III: Model Written Programs

• These model written programs provide general information on a specific topic. Users should revise them accordingly. Care should be taken to ensure that state-plan OSHA requirements are included in revisions.
• These model programs are specific to general industry (shop) work settings as they relate to OSHA compliance. In some instances, OSHA has different requirements for shops versus construction jobsites. For example, as of November 2008, the OSHA general industry standards for hearing conservation, fall protection, confined space entry, and personal protective equipment are different (often more strict) than OSHA standards for construction jobsites. However, several programs including recordkeeping and hazard communication have the same requirements for both shops and construction jobsites.

Part IV: Additional Information

• This section contains checklists and PowerPoint® presentations. The checklists can be modified and used as good tools for hazard recognition purposes. The PowerPoint® presentations are intended to be used as part of a comprehensive safety and health training program that goes beyond toolbox talks. Companies are encouraged to “take training beyond toolbox talks” and provide more classroom and hands-on training.
• A compliance guideline for the Hazard Communication standard and an OSHA publication on detailed information on selection of personal protective equipment is also provided.
• SMACNA Safety Bulletins and newsletter articles – various Safety Bulletins and newsletter articles produced by SMACNA are also provided in this section. The bulletins and articles cover a variety of topics and issues that may be helpful in developing and implementing a safety and health program.