Your Policy

The hallmark of every successful management is top management s active and aggressive commitment to the safety process, where they demonstrate their involvement by following all safety rules. This commitment, in turn, influences the actions of managers, supervisors, and employees. It ultimately determines the effectiveness of your management system to minimize incidents and reduce the variations in the injuries. 

Once you developed your policy, it then must be communicated. This is one of the things that we often forget. However, a successful company makes sure that workplace safety is integrated into all functional areas of the operation, for example, production, sales, and quality. If your policy statement makes this clear, it will be easier for employees to choose the correct actions when any conflict arises between safety and other functions. The following is one example of a policy statement that conveys this message [2]  

People are our most important resource. Our company s principal responsibility is the safety and health of our employees. Every 

Define safety responsibilities for all levels of the organization for example, make sure that safety is a line management function. 

Develop upstream measures for example, number of reports of hazards/ suggestions, number of committee projects/successes, number of related specific activities, etc. 

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Conduct periodic reviews of your policies and objectives. 

There is no requirement for you to state the policies to meet each clause of the standard but many organizations in fact do just this. ISO 9001 requires the manual to cover the requirements of the standard and ISO 10013 gives an example of how this may be done. ISO 10013, however, points you in the direction of producing a quality manual which is structured in the sequence of the key elements of the standard rather than the operations of your business. This is fine for third party auditors but not for your staff, who will probably want to know your policy on some aspect of your operations in order to make a certain decision. This is where you need operational quality policies organized around the operations of the business - such an approach is deemed acceptable in ISO 10013. 

To make this method better than the others, you would need to number all your policies. 

To keep your policies and procedures up-to-date with the latest industry practices you should provide a means of identifying new developments. This can be done by scanning journals, attending seminars and conferences, and generally maintaining an awareness of developments in quality management and technologies relevant to your business. 

This questionnaire is somewhat limited as there are only three specific servicing requirements in the standard. As other parts of the standard apply to servicing you should consult the relevant questionnaires to help establish your policies in this area. 

Your policy statement should describe your arrangements, ie the systems and procedures you have in place for ensuring employees health and safety. 

You need to record the significant findings of your risk assessments in a separate document. Your policy statement only records yoir anangements for ensuring the assessments are done, and are kept up to date. 

Transferring risk may sound easy. All you need is to find the right policy, for the right need, at the right cost. Write a check once a year and hope nothing happens. Of course, it is more complicated than this. When you retire, you must find policies that cover new risks or close gaps in existing ones. Policies can be deceptive. You may think you are fully covered when you re not. There are sometimes exclusions that limit your policy. Also, you must consider cost. It s impossible to live with style if you spend all your discretionary income on insurance premiums. 

I I Beware of a replacement offer. If someone tries to replace your policy, be suspicious—especially in health insurance. Have someone who is qualified help you make a comparison. 

Do your current procedures comply with your policies and standards ... 

Tbp management commitment — If your policies and procedures implementation initiative is dependent solely on your leadership, it wiU die and your policies will ultimately be ineffective. The policies and procediires need to be accepted on a companywide basis. 

Therefore, they are your most valuable source of job-specific and safety-related information. Your policies should enable employees to make decisions that positively impact safety and the bottom-line. 

Training and tools — Every employee (from your driver to front-line supervisors) requires training in your written safety policies and procedures. Training is necessary in order to reach a common understanding of the goals and objectives of your policies, and the means to attain them. 

Management needs to also realize that training does not stop and can never be considered finished. Continual training is done through management constantly reinforcing the safe behavior dictated by your policies and through open, up-ff ont, and two-way communication. 

Safety manager is responsible for being constantly visible and leading by example. You need to be an enthusiastic advocate of your policies. You are also responsible for developing and implementing your safety policies. 

I Make sure your written safety policies never become out-of-date or ineffectual. Keep your policies and procedures current with changes in regulations and the changing needs of your employees and customers. 

Keep a file for all company memos, directives, articles, and other items or sources that have initiated a change in your policies for future reference. 

Establish a regular schedule for reviewing your policies. Policy reviews should become a routine part of your role. Send a memo out to managers prior to your reviews asking for input and updates. 

Policy reviews provide a means of control over your policies. As part of your overall safety program, reviews are necessary for several reasons. They ... 

Make all employees aware that the organization is serious regarding adherence to, and enforcement of, your policies and... 

We demonstrated how to develop your policies and establish your safety goals. Next, we outlined an implementation and employee training strategy. 

Making sure your safety policies are measurable was the next element discussed. Finally, the importance of reviewing your policies for effectiveness and bottom-line results and, when needed, making adjustments, was highlighted. 

Dilute and negative You may, but are not required to, direct the employee to take another test immediately. Whatever you decide to do (retest or not to retest) must be in your policy and be consistently applied. See 40.197 for details. 

The identity of the person designated by the employer to answer driver questions about the materials. (1) Your written drug and alcohol policy must identify your drug and alcohol answer person. This individual should be identified in your policy by name, title, or both. This individual does not necessarily have to be your organization s designated employee representative (DER), but having your answer person and DER be one in the same makes sense, and in most motor carrier operations, this individual is YOU — the company s safety professional. 

The categories of drivers who are subject to the provisions of this part. (2) Your policy must list (not by name, but by type) the drivers you use who are affected by your written drug and alcohol policy. This means if your company uses owner operators, leased drivers, part-time or seasonal drivers, etc., the type(s) of driver must be listed in your policy. 

Sufficient information about the safety-sensitive functions performed by those drivers to make clear what period of the work day the driver is required to be in compliance with this part. (3) This is a fairly straightforward element of your written drug and alcohol policy. Your policy must state when your affected drivers must be in compliance with the requirements of Part 382. In the case of drugs, basically all on-duty time. In the case of alcohol, all time immediately before, during, and after the performance of any safety-sensitive function, and four hours prior to reporting for duty. Keep in mind, your policy can go above and beyond this minimum requirement. 

The consequences for drivers found to have violated Subpart B of this Part, including the requirement that the driver be removed immediately from safety-sensitive functions, and the procedures under Part 40, Subpart 0, of this title. (9) Your policy must clearly state what the consequences are to a driver who violates the prohibitions listed in Subpart B of Part 382. For carriers that have a zero-tolerance policy, this is simple — you will provide the driver with a list of substance abuse professionals, and then terminate employment. For carriers that do not terminate, you must detail your SAP program in your written policy. 

The consequences for drivers found to have an alcohol concentration of 0.02 or greater but less than 0.04. (10) At a minimum, drivers who test with a BAG of between 0.02 and 0.04 are prohibited from performing any safety-sensitive function for a minimum of 24 hours. This is a regulatory requirement. But are there any other consequences, as a matter of company policy, for these drivers Any additional consequence — whether in the form of a written warning, suspension, etc. — must be listed in your policy. 

Develop a detailed company policy that shows zero tolerance for drug use and alcohol abuse while maintaining compliance with the minimum requirements of the DOT regulations. To reduce your liability, go above and beyond the regulations. Educate your drivers on those policies and make sure they know what is expected of them and what actions are prohibited by the regulations and your policies. 

Since it should be your policy that your drivers are required to obey all posted speed limits, the use of any type of radar detection device is, by definition, unnecessary. 

After you get into the habit of doing this self-audit, you could expand it to include more regulations than just those that are acute or critical. And finally, remember to review your policies and procedures at the same time you do the selfaudit. 

To be effective, it is important that your safety policy be communicated to all employees. You can communicate your policy by words, actions, and setting an example. The following sections will discuss these options ... 

You want to include the written policy statement in all new-employee orientation. In addition, make sure to post a signed policy statement on the employee information bulletin boards. You can also communicate your safety policy by adding it to your company letterhead and/or posting your policy on the company s Web site, if you have one. This is an added value to the safety in your organization [2]. 

What you do, or fail to do, speaks louder than what you say and do not say (or write). Demonstrate your concern for your employees by committing resources to the prevention and control of unsafe conditions, to safe work practices, personal protective equipment (PPE) where needed, and training. Whenever you demonstrate a willingness to put safety before short-term production goals, your actions forcefully and clearly state and dehne your policy [2]. 

Now that your policy statement has been developed and communicated, you are ready to define your goals and objectives. These goals and objectives provide you the direction that you can take to reach your destination. It is the results that you want your program to achieve. Refer to Table 5-2. 

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