ANN ARBOR, MI — Ken Zans made one point very clear during the Conference on Worker Safety and OSHA Compliance: “Businesses need to create a corporate culture of safety.”

He asked attendees, “Can an outsider or visitor to your business recognize your corporate culture of safety, i.e., signage or employees wearing protective clothing?” He pointed to signs listing the number of accident-free workdays and safety glasses as examples.

This “culture” must also be supported by written policies and procedures, according to Zans. The policies should include a named person for the company’s safety and health program, although it is not necessary to have an employee dedicated full time to this department, he noted. The company also must delineate accountability and responsibility for safety, with the ultimate responsibility lying with the supervisors. This should be written into their job descriptions, Zans asserted.

Furthermore, money and time must be budgeted for the safety and health program, said Zans, and events such as regular audits and safety meetings must be planned.


“Have a safety committee,” Zans urged. “It is mandatory in Michigan and 22 other states that have OSHA programs. There should be a representation ratio on the committee of two-thirds workers and one-third management. Every department should be represented, and membership should rotate on a regular basis.”

Zans said there are ways to get employees involved in safety programs, such as suggestion boxes, hazard recognition, and a “near miss” report (which doesn’t involve naming employees or drawing fines). Incentive programs are not a favorite of Zans.

“Why should an employer reward an employee for doing what they are paid to do?” he asked.

Rather than incentives, Zans suggested having supervisors hand out “mad money” to employees who are doing the right things at work. Employees can redeem the money for a gift from a gift catalog. Or supervisors can hand out “time-off” cards, which employees can use to accumulate time off with pay.

Zans said that all of these things are noticed by OSHA. “We need to give OSHA something to look at when they make a value judgment about a company’s safety program,” he said.


Zans said that each job description needs a job hazard analysis (JHA), which basically outlines each step that is needed to avoid job hazards, including the use of personal protection equipment (PPE). He added a word of caution about PPE.

“OSHA will see companies that add extra gear to fight a hazard and they will ask; ‘Why not just get rid of the hazard?’

“The analysis process may include PPEs, but it may also lead to ways to identify the hazard. The idea of the process is to look at each step rather than the whole picture. You might miss something if you don’t.”

Publication date: 08/12/2002