This article was originally posted at some time between 2015 and September, 2020. It is being re-posted now as part of our website reconstruction. Some of the dates mentioned in this article may reference the time period from which it was originally posted.
I get calls almost every week, asking me if I have a template for Minnesota OSHA’s AWAIR program. Like many other safety consultants in Minnesota and elsewhere, I use templates for my own personal use, but I rarely give them out because it’s so easy to abuse them. Plus, giving away products is bad for business ?
One of the reasons I don’t like to see people use templates, is that there’s really not much need for them, except to get a basic idea of what your actual program needs to look like and contain. It’s fairly easy to write your own AWAIR program, without a template and without the help of a safety consultant, if you just know a little bit about the regulation with which you’re trying to comply.
So with that in mind, let’s talk about the MN OSHA’s AWAIR law.
First of all, AWAIR is an acronym for “A Workplace Accident and Injury Reduction” program. The law was created by, and is enforced by Minnesota OSHA so it doesn’t apply in other states, although many other states have similar requirements.
You are covered by the AWAIR law if your company’s North American Industrial Classification System (NAICS) is included here. But keep in mind the list changes every two years, with NAICS codes being added or deleted. If your NAICS code gets added, you will have six months to come into full compliance with the law.
If you’re covered by the law, you need to develop a formal, written AWAIR program, that describes the following:
- how managers, supervisors and employees are responsible for implementing the program and how continued participation of management will be established, measured and maintained; In this section, describe the general and specific responsibilities that exist for all levels of employees in the organization. For instance, management will be responsible for authorizing and funding the AWAIR program, creating a culture of safety and compliance, etc. Supervisors will serve as safety officials in the areas they work, and will enforce safety rules, provide coaching, and training, etc. Employees will observe all safety regulations, attend safety training, report hazards and injuries, etc.
- the methods used to identify, analyze and control new or existing hazards, conditions and operations; In this section, describe what your company does to make sure the work environment is safe. Perhaps, this includes safety inspections by safety committee members or vendors like safety consultants, employee safety suggestions, employee hazard reports, etc. Don’t forget to include what metrics will be used to monitor safety performance.
- how the plan will be communicated to all affected employees so they are informed of work-related hazards and controls; How will key safety messages and training on the AWAIR program and other safety topics be communicated to people? Perhaps you might discuss ongoing safety training for new and existing employees, handbooks, safety posters, etc.
- how workplace accidents will be investigated and corrective action implemented; Describe how injuries and illnesses are to be reported to the employer (reported to whom, and how? Who completed the first report on injury?). Describe the process for investigating these incidents and how corrective action will be applied.
- how safe work practices and rules will be enforced. What are the safety rules and how are they communicated? What is the disciplinary policy? Make sure this section is consistent with your HR policies!
Whenever appropriate, incorporate who will be responsible for what, and be sure those responsibilities are assigned to employees, and not external staff like safety consultants. Also, don’t forget timelines.
For more information, you can review MN OSHA’s AWAIR web page here.
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