Frank Marino, CSP •

Enforcement Policies - A Vital Key to Success

At the recent CRCA tradeshow, the safety committee tackled a very difficult subject - Fall protection for repair crews. There was plenty of participation and discussion regarding these activities; including the industry base explaining to the OSHA participants the ongoing challenges associated with this type. Although many CRCA contractors are dealing with this continually evolving issue, there are still just as many contractors dealing with a more “fundamental” issue. Because after the presentation, I was approached with a question I'd been asked several times before. This question seems to come up no matter the presentation, and is an indication of the frustration held by many roofing contractors: “I train my employees, I buy them all the right equipment, and they still do not follow the rules!”

The question (which was really more of a statement) was greeted with a mutual understanding from many of the other attendees. I wasn't planning on addressing this issue at all, but based on the crowds reaction, I got right to it.

One key fundamental of an effective safety & health program includes an effective enforcement program. Many contractors, no matter the industry, don't want to accept this is the solution to their continuing problem. However, contrary to popular belief, enforcement does not always mean firing an employee for not wearing safety glasses or shutting down and lecturing a crew following an OSHA inspection. It has been my experience that enforcement programs fail too often because management is not set up for success. When a supervisor is faced with the decision to “enforce the program ” by removing an employee from the jobsite for a violation and therefore jeopardizing the production schedule, you may get the common response of “just wear them from now on ” with little or no follow up. This response not only weakens the overall safety program and will continue to deteriorate the companies safety culture, it also sends a mixed message to the rest of the employees on the crew that safety is only important when it is convenient. I do not believe supervisors want this to happen, but they may be set up for failure from the beginning with an ineffective program. An effective enforcement program includes a systematic, consistent, and quantitative program that is applied to all employees equally. Most programs consist of multi-tiered accountability systems that include steps such as:

  • 1st violation - verbal reprimand
  • 2nd violation - written reprimand
  • 3rd violation - mandatory safety training
  • 4th violation - suspension or termination

The listed approach provides contractors with several advantages. It provides a means to hold employees accountable for “making a mistake”. If that same “mistake” happens 3 more times, we could all agree that employee may not be right for your company. However you choose to spell out your enforcement program, remember these important points:

  • Be Consistent – An employee can sense when they are not being treated the same as their fellow worker.
  • Make it Fair – It has been my experience that even cases where employees do not like the program, their perception of it being fair will win their commitment.
  • Keep it Simple - Do not get in the habit of making exceptions for certain instances. A traditional 4-step process should take into consideration a majority of your foreseeable program violations. If a company chooses to write a program that immediately suspends or terminates an employee for violations such a fall protection or other serious issues, keeping to steps 1 & 2 listed above will keep your program on the right track
  • Training - Ensure that you train all employees on the enforcement program so they know what they can expect.

The development and implementation of this program may be easier said than done. As a matter of fact, I would agree that it is. However, I have never worked with a successful program that did not have an effective enforcement policy as part of its foundation. Getting started with an enforcement program is by no means easy, and things may even get a little worse before it gets better, but maintaining an effective enforcement program is a proven method to maintaining compliance on the roof resulting in a safe & healthy workplace for all employees.

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