The Bottom Line: Glass and glazing companies should have comprehensive safety plans that cover hazard avoidance, equipment maintenance, reporting and OSHA compliance to prevent accidents and ensure proper incident response when workplace injuries occur.
The adage goes, accidents hurt but safety doesn’t. But when worksite accidents do happen, important and immediate risk management steps are needed. Laws may vary from state to state, but a review of generally applicable duties for workplace safety and incident response is a best practice for all glass and glazing companies.
Working with glass, whether in the factory or on a jobsite, can be dangerous. Among the 10 most cited Occupational Safety and Health Administration violations year after year are failings in jobsite controls, personal protective equipment and machine guards used in manufacturing. Whether it is fall/scaffolding protection, hazard communication, or eye and face protection, safety concerns vital to the glass industry are being cited on a regular basis.
OSHA and its local state analog have regulations applicable to specific industries. Broadly speaking, many of these requirements can be grouped into six large categories.
Safety categories
1 | Hazard mitigation
Employers must review workplaces and job functions to remove or mitigate recognized hazards. This includes complying with specific OSHA requirements for the conditions at a site, as well as how the work itself is performed.
2 | Equipment maintenance
Any tools or equipment used in a job must be safe and well maintained. This does not inherently mean new, but sometimes developments in tools or equipment make replacement the safest option.
3 | Hazard warning
Potential hazards present in the work and equipment being used must be given to all employees. These warnings must be clear and in a language that the workers can understand. These general notice sections are also where the required OSHA poster displays are found, and complying with those seemingly mundane requirements should not be overlooked.
4 | Accident documentation
When accidents do happen, records of work-related incident and injuries must be maintained if an employer meets certain minimum thresholds. Where applicable, logs of injuries and illness can be required by OSHA and must be turned over for review. These logs can also be used to meet employee disclosure demands, when made.
5 | Incident reporting
Serious incidents require immediate action. Any workplace fatality must be reported to OSHA within eight hours, and serious dismemberment or disfiguring injuries reported within 24 hours.
6 | Process cooperation
OSHA can compel access to injury and exposure records, but cooperation can smooth the process when those record requests are reasonable. Inspection and access to site work is also a required component. Beyond the agency itself, protecting individual workers who issue complaints is mandatory.
Creating a response tool
These categories are general descriptors and do not represent a full, OSHA-compliant program. In fact, OSHA itself recommends employers prepare and publish a health and safety program that is specific to the industry and job functions of an employer. Regular use and updating of that kind of plan can also be a helpful response tool when legal contests arise or when incidents happen.
Thorough health and safety plans should identify responsibilities when a workplace incident happens. Preparing this plan process can also prove a valuable tool because it requires thinking through the formal requirements of an incident response and helps develop mitigation strategies. This is because while nearly all states require worker’s compensation insurance that will respond when an incident happens, from a risk management perspective, it can be strategic to supplement the carrier’s actions.
Responding to incidents
The immediate response to any workplace incident must treat the injured and protect others who might be exposed. Programs should define emergency treatment response obligations and the requirement to get expert help (like 911), as crucial first steps. Beyond the injury, there should be an assessment of the site to ensure the threat of injury to others is limited as much as possible.
Once immediate health and safety issues are addressed, gather information and evidence. Whether or not a formal legal claim may come in the future, the simple happening of an incident provides an opportunity to learn. Employers can:
- Take photos of the site.
- Preserve equipment and machinery used in the accident with as little change as possible.
- Collect witness statements.
Each of these steps provides a chance to record what happened close in time to the incident, and an opportunity to revisit the incident later to identify chances to improve safety or develop new processes.
After those immediate steps, a plan should specify reporting to any worker’s compensation carrier and OSHA. Cooperating with the carrier and any investigating entity is crucial, and notice is the first step in that process. The carrier can also provide guidance on requirements for protection of the injured worker’s position and potential workplace accommodations that may be needed based on the injury.
Educating employees
Good health and safety plans also are important to employee education. Specific requirements to report any incident and secure medical treatment help protect workers and those who hire them. In addition, advisories against certain conduct that can threaten safety and workman’s compensation coverage are also needed—things like substance abuse, intentional misconduct or violation of an established company policy can lead to injuries that have few remedies. Cautions against fraud are also needed.
Accidents happen. OSHA wants to help employers prevent those incidents. The best help, however, comes from health and safety planning specific to your company. A plan that provides incident guidance and education for employees can provide real safety.
