Developing a Safety and Health Plan is similar to researching a new business plan. Step One is to observe the playing field and assess what’s already in place. A program researcher must be able to see the whole field at once. A business plan begins with a simple concept: Provide a product or service because no one else is doing it, or if they are, they aren’t meeting market demands. Likewise, a consciously developed SHP looks for what is missing and focuses on either improving safe work practices or installing adequate hazard controls. It is also a tool for increasing profitability by reducing lost time, saving material and insurance overhead costs, and maximizing manpower potential.

When I ask my contractors where they figure to start with the SHP, they usually pull out their old program from the bottom shelf and, with a big smile, announce, “Right here!” dropping the binder in a cloud of rock-salt dust. This is NOT a renovation job. The best decision you can make is to take a new approach to workplace safety and health. Sponsor a new attitude. Lead your employees by example. Approach your workers with confidence and admit to them, “I don’t know where this will take us, but together we can make ours the safest and healthiest work sites to be found anywhere.”

Audit Notification

Inform your workers that you will personally be visiting every project over the next several months. Yes, this is a long-term effort. You may choose to issue an interim version before completion. A SHP should change as your jobs change. Whenever you’re on site, look and listen, with an emphasis on listen.

During an audit, leave your foremen and project superintendents alone and tell them to do likewise. You are not on site to answer their questions about the plans or specs, give them change orders or inform them of delivery schedules. Your job is simply to record, not enforce. There are no accusations whenever audits are conducted. Suggestions are the strongest management tool you should use, but try to minimize them.

Once your workers know that your intent in a safety audit is to view working conditions and not to catch them in some sort of compromising act, they will develop a level of trust for your actions. Be careful to remain impartial and objective. It will be difficult, but if you send someone else to perform audits you’re losing a prime opportunity to show your employees that you are involved in their safety and health. It may be one of the only chances you might have to give your company a complete safety “check-up.”

Audit Attitude

The best auditors I have ever known resemble professional photographers.

They have a keen ability to blend into their surroundings without distracting others in their tasks. They don’t hurry needlessly or stand out in the overall view. And they document everything.

These are the only instances when you should inject yourself personally into the project, for the safety of all those exposed. I always do this directly with all of the affected employee(s) rather than running to the foreman. This puts me on their level, eye-to-eye. I am not presenting myself as someone micro-managing the situation from a distance, but rather a concerned partner in the company’s overall safety. I often break the ice (which tends to surface in these episodes) by inviting everyone to stop what they are doing and take a “safety walk” around the project limit lines with me.

Also, take some time to practice competent audit speech. It’s just plain English, but with a twist. Avoid accusatory terms such as “should have,” “ought to,” “never” and “must.” The other grammatical change that you should try to master is replacing “you” with “us.” Removing the “them-vs.-us” syndrome will be difficult at first, but after a while, you’ll start believing in the “us” and the “you” will fade away. These men and women on your job sites ARE your company. That’s all there is to it.

Audit Scheduling

You might try to convince yourself that as CEO, your time is much too valuable to lend to this type of work. Don’t believe it. You’re the only one who can slog through this. You can use the services of a safety specialist as a consultant, but you must match his mileage if this is going to succeed. I suggest most contractors begin with 8 hours for week one, 16 hours for weeks two and three and finally 24 hours each week thereafter until the audit is completed. Don’t take your audit time in a straight-line schedule either. Move around the clock as you move around the area. Notice how the same job “feels” in the morning as compared to the afternoon, when the blood sugar levels drop and the January wind picks up.

If your crews travel long distances, don’t reserve a room at the Marriott if they are across town at Motel-6. If they start at 6:00 am on hot summer days, get to the job at 5:30 with coffee and fat-pills (donuts). Take a half-hour to introduce yourself. You might be surprised at how many of your employees only know you as a name at the bottom of their check. Come prepared to give a 10-minute safety talk on something pertinent to their job. Give each foreman a copy of the OSHA Construction Standard and teach them how to use it. Let them know you are familiar with the OSHA standards and want to construct a new or revised SHP with their help. Admit that you can’t do it alone. This one will require the entire team to complete.

The Mechanics of an Audit

Teaching yourself how to observe is not easy. Safety audits are just as often focused on potential hazards as they are on existing hazards. For instance, as the 60-ton crane is delivered on site, even before it is unloaded, the operator should be walking the site identifying potential and existing hazards, such as low- and high-voltage lines, overhead obstructions, unstable soils and interfering traffic patterns. Observation may be just as effective when peripheral vision is utilized.

Here’s a simple visual exercise. Get a comfortable seat somewhere with a good overall view of the site and where you won’t be readily disturbed. Close your eyes, relax and take a few deep, slow breaths and give yourself permission to forget about all your responsibilities and hectic schedule. Now open your eyes slowly. Not all the way at first, but just until there are a few general darkened shapes and lighter fields visible. Stay at that level of perception for a moment. Then very slowly start to bring the view into focus.

When the first identifiable object comes into your perception, stop a while and concentrate on just that object, like a dumpster or fork lift. Look at all of its parts, one at a time. Then increase your focus until some other item appears, like a worker uncoiling air lines from a compressor. Look at the smallest details, such as the hose couplings, the air pressure gauge, the color of the worker’s gloves, the decals on his hard hat.

Continue this process until your vision field has grown to the view in front of you. Now notice how much detail there appears to be in front of you compared to your perceptions before you closed your eyes. Now there is an intensity of detail and an increased perception of relationships you didn’t perceive before. In a short amount of time, however, without you even noticing it, this will fade until a more familiar and somewhat more comfortable level of “seeing” returns. But the more you practice this exercise, the quicker a high level of perception is reached and the longer it remains in your conscious mind.

Recognition vs. Identification

OK, you might ask, now what? At this elevated level of perception, we can better achieve the goals we set out to reach in a site audit. Recognition and identification are separate functions of the human brain. Every hazard is recognized by the human brain by identifying certain contributory effects. The causes of these effects is what a functional audit should clearly identify. We call these the root causes.

Hazard identification is achieved by analysis of the two primary factors — time and space — which either lead directly to an accident, come close to each other in a near-miss or slightly avoid each other in a non-event. I define a non-event as an episode that becomes non-hazardous due to either a delay or acceleration in temporal events or a detour in spatial routes.

A simple test to discern between hazard recognition and hazard identification is to ask the question: How? If the answer is followed by another “how?”, then you must continue the analysis. For instance, you observe a worker standing next to a gas-powered mixer, close to its V-belt drive pulley. How could he be injured? You recognize the existing “caught-in” hazard at the pinch point of the belt and the spokes of the pulley. How could he be injured? You recognize that he must stand within a body’s length of the pinch point in order to operate the mixer. His spatial relationship to the hazard during its operation must be close enough to become injured. He must stand in that location in order to operate while the machine is running. The temporal relationship is also established.

We have identified the root cause of a potential accident: The last question: How can he work safely next to the hazardous machine while it is still running? A suitable guard must be devised to allow the machine to run properly and without restricting the worker from operating the machine. In this simple way, we can follow hazard recognition into hazard identification. Once the root cause is identified, then the hazard abatement method becomes obvious and doable.

Assembling an Audit-based Program

If an SHP is going to be effective, the site safety audits that proceed it, must be comprehensive and detailed. For instance, creating a mandatory hard-hat policy on all company works sites regardless of hazard identification may make a policy simpler than listing 30 separately observed conditions under which hardhats may prevent injuries or save lives. However, further identification may indicate that it was not that the worker was not wearing his hard hat, but rather wearing it improperly, with the suspension reversed. This can lead to eye injuries, not head injuries. Therefore, a competent audit would identify insufficient employee training and implementation on the part of the site super or foreman as the potential root causes of injury. Then the personal protective equipment section of the SHP should reflect clear and understandable training goals for the employees as well as simple inspection criteria for the employer-designated competent personnel for personal protective equipment on site.

Not only will you be identifying those hazards that are typically encountered by your workers on a regular basis, you will also identify those hazards to which your employees are infrequently exposed.

Sometimes an employer finds it convenient to take the same approach OSHA utilizes in construction-focused inspections in recognition of the five major root causes of fatalities on the work site: falls from heights, struck-by, caught in/between, electrocution, and other. This is often a simple method to initiate, but often leads to some confusing research on the part of your employees when they want to specifically determine what is expected of them while erecting scaffolding, operating a fork lift or installing torch-applied membrane, etc.

Another method of establishing audits by modules is utilizing the index of subparts in OSHA’s 29 CFR, Parts 1926 and 1910. There are 24 out of a total of 26 Subparts in Part 1926 (Construction) standard that may or may not be applicable to the scope of work in your average roofing contract. Subparts R (Steel Erection), T (Demolition), and Q (Concrete and Masonry Construction ) may have some applicability under certain contractual conditions and workplace exposures.

The most important aspect to any audit is veracity. Does your audit accurately reflect the daily hazardous exposures encountered by your employees? Is there any way in which your crews operate that could be improved to reduce their hazardous exposures? Is there any potential for site conditions to change and affect the worker’s security? Is every employee trained and prepared to react appropriately to any emergency situation?


While there are only three ways out of any accident once it has occurred (injury, illness or death) there are an infinite number of ways to avoid the time/space conjunctures leading up to that accident. Becoming compliant with the OSHA standards will go a long way to reaching your goal of an effective SHP. Constant vigilance and the flexibility to change procedures with conditions will carry you even further. Compliance with the standards is based on the Three E’s: Educate your workforce; encourage your workers to enact the practices they’ve been taught in the SHP; and make every effort to enable your workers to enact the practices in which they’ve been educated.

Remember that the test of any comprehensive safety and health program is whether or not it “lives, breathes and bleeds,” so involve everyone in the process. This safety audit will eventually form the backbone of your written program. For every employee who is not asked for his or her input, there is a valuable asset lost. Unfortunately, for every employee who is not involved in his own personal safety, there may be even a higher price to pay. Begin your site safety audits tomorrow and keep them going.