Buyer Beware - Safety Manuals: My Two Cents
There is an adage that rings so very true with many things, and it is that, “Things are not always as they seem; the first appearance deceives many.”
On many occasions I have had the unpleasant task of informing clients that the safety manual that they have paid good money for, is not worth the cost of the paper it is written on. The reason that this is so prevalent is that the person selling the manual is not doing their job and checking on the company’s operations prior to writing the document. Rather they are providing an off the shelf manual that they are presenting as “comprehensive” for the client. Instead, the reality is that their client is receiving a general document that has a logo inserted, company names put into the “Insert Company Name Here”, and signatures pasted in place.
If you are trying to create a proper safety program for your company this will require not only visits by your consultant to observe your operations, discussions with the employees, and a review of the various types of equipment used, to determine what the hazard controls are. You see, the process to create a health and safety program involves the review of the operations, determining what the hazards are, and then implementing controls for the danger associated with the work. If a person tells you that they can assess your operations and provide you with a “comprehensive health and safety program that meets your legislated responsibilities”, without knowing what equipment is being used or what the operations entail, then they probably also have some very nice land for you, with a great view of the water, that is very cheap.
Why is it so important for your consultant to check out the operations? It is because even though you may be in the same industry, and doing the same thing, you may do it differently. This leads to unique differences in operational activities that will result in different documentation (e.g. Safe Job Procedures, maintenance schedules, training, etc.) as each manufacturer has different requirements. While some items are designed to provide the same end result (e.g. fire a nail in to a piece of wood) it may do so with a substantially different procedure. This results in a “All things are not created equal” issue as the operational differences are unique. As an employer you are obligated to ensure that all employees are aware of the dangers associated with their work and that they are “competent” to do the tasks as defined in the Alberta OHS Act. If you do not ensure this, then you are not in compliance no matter what your expert is telling you.
Last but not least is the adage “Ignorance of the law excuses no one”. This is a legal principle holding that a person who is unaware of a law may not escape liability for violating that law merely because one was unaware of its content. Even though the manual purchased has a professional appearance and uses technical language, it may not meet the client’s obligations as outlined in the legislation. In plain language it would not hold up in a court of law should something go wrong. This results in liability for the person purchasing the manual. This highlights why an organization that purchases this documentation from a provider must verify that it is meeting its legal requirements. Even though someone may present themselves as a professional, it is up to the company to ensure that the documentation provided meets the requirements of the legislation.
If you think it is expensive to hire a professional, just wait till you hire an amateur.
