OSHA requires all employers to maintain safety communications regardless of the type of business.

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Your Safety Communications must communicate in a form readily understandable (written, verbal or otherwise), on occupational safety and health matters, and encourage employees to inform management about hazards without fear of reprisal.

The following tips for managing a successful safety communications program be found at Cal-OSHA.

Your program must include a system for communicating with employees – in a form readily understandable by all affected employees – on matters relating to occupational safety and health, including provisions designed to encourage employees to inform the employer of hazards at the worksite without fear of reprisal.

While this section does not require employers to establish labor-management safety and health committees, it is an option you should consider. If you choose to do so, remember that employers who elect to use a labor-management safety and health committee to comply with the communication requirements are presumed to be in substantial compliance if the committee:

1. Meets regularly but not less than quarterly.
2. Prepares and makes available to affected employees written records of the safety and health issues discussed at the committee meetings, and maintained for review by the Division upon request.
3. Review results of the periodic scheduled worksite inspections.
4. Reviews investigations of occupational accidents and causes of incidents resulting in occupational injury, occupational illness or exposure to hazardous substances, and where appropriate, submits suggestions to management for the prevention of future incidents.
5. Reviews investigations of alleged hazardous conditions brought to the attention of any committee member. When determined necessary by the committee, it may conduct its own inspection and investigation to assist in remedial solutions.
6. Submits recommendations to assist in the evaluation of employee safety suggestions.
7. Upon request of the Division, verifies abatement action taken by the employer to abate citations issued by the Division.

If your employees are not represented by an agreement with an organized labor union, and part of your employee population is unionized, the establishment of labor-management committees is considerably more complicated. You should request clarification from the Cal/OSHA Consultation Service.

If you elect not to use labor-management safety and health committees, be prepared to formalize and document your required system for communicating with employees.

Here are some helpful tips on complying with this difficult section:

1. Your communication system must be in a form “readily understandable by all affected employees.” This means you should be prepared to communicate with employees in a language they can understand, and if an employee cannot read in any language, you must communicate with him/her orally in a language “readily understandable.” Your communication system must be “designed to encourage employees to inform the employer of hazards at the workplace without fear of reprisal” it must be a two-way system of communication.
2. Schedule general employee meetings at which safety is freely and openly discussed by those present. Such, meetings should be regular, scheduled, and announced to all employees so that maximum employee attendance can be achieved. Remember to do this for all shifts. Many employers find it cost effective to hold such meetings at shift change time, with a brief overlap of schedules to accomplish the meetings. If properly planned, effective safety meetings can be held in a 15 to 20 minute time frame. Concentrate on:
   • Occupational accident and injury history at your own worksite, with possible comparisons to other locations in your company.
   • Feedback from the employee group.
   • Guest speakers from your worker’s compensation insurance carrier or other agencies concerned with safety.
   • Brief audio-visual materials that relate to your industry.
   • Control of the meetings.
   • Stress that the purpose of the meeting is safety. Members of management should attend this meeting.
3. Training programs are excellent vehicles for communicating with employees.
4. Posters and bulletins can be very effective ways of communicating with employees. Useful materials can be obtained from Cal/OSHA, your workers’ compensation insurance carrier, the National Safety Council or other commercial and public service agencies.
5. Newsletters or similar publications devoted to safety are also very effective communication devices. If you cannot devote resources to an entire publication, make safety a featured item in every issue of your company newsletter.
6. A safety suggestion box can be used by employees, anonymously if desired, to communicate their concerns to management.
7. Publish a brief company safety policy or statement informing all employees that safety is a priority issue with management, and urge employees to actively participate in the program for the common good of all concerned. (Model policy, statements are found in Appendix A.)
8. Communicate your concerns about safety to all levels of management.
9. Document all communication efforts, as you will be required to demonstrate that a system of effective communication is in place.