Occupational Health and Safety Compliance

This page of the College Safety and Security Toolkit concerns Occupational Health and Safety Programs.

Occupational health and safety programs are designed to keep employees safe and healthy. They not only protect employees' wellbeing, they also protect the college from costly medical bills, lost productivity, hefty paperwork and steep fines. Protecting employees from injuries is a both a moral obligation and a legal mandate.

Organizational and Legal Framework

Cabinet roles

Your president and other high-level cabinet positions play a vital role in providing financial and campus-wide support for your occupational health and safety program. 

Designated officers

Each college should designate an Occupational Health and Safety Compliance Officer. To be successful, the officer must have both expertise and authority.

Employer/supervisors

College personnel and supervisors are responsible for:

  • Counseling and training employees [note: bookmark to training below.]
  • Documenting accountability, discipline and adherence to standards. [note: bookmark to documentation below]

Occupational Health and Safety Act (OSHA)

In 1970, Congress passed the Occupational Health and Safety Act (OSHA) to develop and enforce workplace safety and health rules throughout the country. The act allows states to run their own safety and health programs as long as standards are equal to or more stringent than OSHA.

Washington Industrial and Safety Act (WISHA)

In 1973, Washington state passed its own version of OSHA —the Washington Industrial Safety and Health Act, or "WISHA." (RCW 49.17). WISHA is enforced by the State Department of Labor & Industries, specifically the agency's Division of Occupational Safety and Health.

WISHA regulation supersedes that of OSHA for Washington state as long as standards are equal to or more stringent than OSHA.

Both OSHA and WISHA place the responsibility for employee safety directly on the employer.

How to Create an Effective Compliance Program

To protect employees' health and safety, you first need to know what hazards they face on the job.

A Job Hazard Analysis (JHA) is one practical approach recommended to identify hazards and possible solutions. During a JHA, each basic step of the job gets reviewed to identify potential hazards and determine the safest way to do the work.

Who is responsible for creating JHAs?

  • Supervisors and safety professionals generally develop the JSAs.
  • JSAs must be reviewed by workers performing the job for feedback and suggestions.

JHA templates

Now that you've conducted a Job Hazard Analysis, find out which rules apply to you.

  • Core rules — Start by reviewing WISHA's Core Rules  They encompass 26 basic health and safety rules. These rules explain the minimum requirements for safe workplaces that employers must follow. They form the basis for virtually all your programs and cover almost everything nonmanufacturing employees need for a safe and healthful workplace.
  • Other rules — You might also need to comply with other rules specific to your workplace. The Department of Labor & Industries created a chart to help you sort through rules according to types of hazards.
  • Helpful tools for specific rules — Pointers on specific rules, from the Department of Labor & Industries.
  • All rules — The entire body of WISHA rules is found in Washington Administrative Code 296.

Hint: To receive email updates, sign up for the Department of Labor & Industries listserv.

WISHA requires employers to keep job sites safe for all employees, whether they work for the employer, a contractor, a subcontractor or someone else. — Department of Labor & Industries Guide to Workplace Safety and Health in Washington State

Accident Prevention Program

All employers in Washington State must create an Accident Prevention Program (APP) — a written plan to prevent accidents, illnesses, and injuries on the job.  Found in the Core Rules, this document:

  • Forms the backbone of your overall safety program.
  • Must be tailored to the needs of your particular workplace or operation and to the types of hazards involved.

At a minimum, it must include a safety orientation and a safety and health committee.

Safety Orientation

Safety and Health Committee

All employers are required to create a Safety and Health Committee. Larger employers must establish a safety committee. Smaller employers have the choice of either establishing a safety committee or holding safety meetings with a management representative present.

You might need to have  supplemental written programs or procedures beyond your accident prevention program. These can be included in your accident prevention program or covered in supplemental documents.

A table created by the Department of Labor & Industries will help you determine additional programs, plans, and other related requirements that might be needed beyond your accident prevention program . 

Examples for colleges include:

  • Hazard Communication
  • Bloodborne Pathogens
  • Respiratory Protection
  • Hearing Protection
  • Chemical Hygiene

Example templates for supplemental programs and plans.

More example templates for supplemental programs and plans.

The type of training you provide depends on the hazards your employees face and the rules associated with those hazards.

The Department of Labor & Industries Offers:

L&I's Division of Occupational Safety & Health (DOSH) Consultation Program offers you no-fee professional advice and assistance to establish or strengthen your workplace safety and health program. You cannot be fined by a consultant as a result of the consultation. You will be required to correct serious hazards, but you face no financial penalties. 

Three types of consultations are offered:

  • Safety and/or health
  • Risk management (for example, the impact injuries have on workers' compensation)
  • Sprains and strains (ergonomics)

Establish a method for employees to report accidents and near misses. An accident report form can help document the findings of an investigation into an accident or incident in your workplace.

Accident investigation basics.

Supply mandatory forms to the Department of Labor & Industries.

To stay on-task with compliance requirements:

  • Develop a timetable spreadsheet to ensure reoccurring compliance actions for all program. 
  • Consider using a Microsoft Outlook calendar to schedule and prompt compliance actions (training, inspections, equipment calibrations, etc...)
  • Develop a system to document completion of required compliance actions. An example would be the Megamations work-order system. (This does not constitute an endorsement of this product.)

Members of the Safety and Security Emergency Management Committee offer this advice:

Try to build rapport with compliance officials.

Be willing to comply with violations as soon as possible.

  • Articulate and provide documentation of your intent to comply.
  • Check to see if there alternatives for compliance. 

Bring in experts specific to the occupational/health issue.

Be willing to use the other colleges as resources to help compliance

Consider a full-time dedicated Occupational Health and Safety professional

Document:

  • All plans
  • All training
  • All inspections
  • All incident and accident investigations
  • All program reviews
  • Employee medical documentation related to occupational health safety