OSHA regularly updates its standards, often making small corrections to the regulatory text. On February 17, 2020, OSHA published technical corrections and amendments to 27 OSHA standards and regulations. Sixteen of these standards and regulations were specific to the construction industry. Have you updated your programs and policies to reflect these changes?

If you haven't, this is a good reminder for employers to perform housekeeping of their standard operating procedures, safety plans and policies, and company rules.

Here are some tips to follow:

• Don’t procrastinate. If your corporate board, the state, or your client needs to review updates to your plans or rules, work this into your planning timeline so your workers have access to updates as soon as possible.
• Create a practice in your company to review all plans, policies, and rules at least once per year. Create a revision tracking page and include all departments and your employee safety committee in your annual review process.
• Make sure that workers can understand your rules and policies. Training and programs look good on paper but are meaningless unless your employees understand and apply their training to their jobs. Use plain English that your workers can easily follow.
• Remove policies that are outdated and not needed any longer. Has a business division closed that's still addressed in your rules and plans? Make sure to address any new areas of business expansion. I worked in a facility on the East Coast with all of the programs/policies based on their California facilities and Cal-OSHA, many of which did not apply to my facility due to an entirely different set of hazards.
• Make sure your rules and plans don’t conflict with the law. Perform due diligence and make sure your company is following current laws. Check OSHA, state-OSHA plans, building codes, consensus standards, and state or federal laws for updates. Ask J. J. Keller and Associates for help understanding the resources as needed.

Every employer has a duty to provide workers with clear direction about how to do their jobs safely. Outdated policies, rules, and plans can cause life-changing and sometimes fatal errors that impact not only the victim but other employees as well.

Key to remember: Review and update all rules, programs, plans, and policies annually. Take time to check in with employees and include their input in your annual review.