b'Garys CornerupdateGary Auman, MRCA Legal CounselSafety Deserves More Than Lip Service whether or not, they are being effectively trained? Believe Were you at the MRCA Annual Convention in Omaha inme, you would not be unique if you were not aware of the October? If you were, congratulations; if you were not, youdetails of the efforts your company is making in safety. missed a great show and valuable educational opportunities.Quite a few years ago I represented a client in an OSHA So,whereamIgoingwiththis?Iam,ofcourse,leadinginvestigation. During that investigation the president of the toadiscussiononsafety.Quiteabitofinformationwascompany, in my presence, was asked by the OSHA compliance presented at the convention concerning safety. Because ofofficer if he would show him his safety program. I asked to see timelimitations(somethingweallhave)noteverythingit before it was handed to the compliance officer and I found concerning safety could be covered. I am going to take thethat it was nothing more than the entire OSHA construction opportunity to use this column over the next several issuesstandard.Onlyitwasjustreprintedinaslightlydifferent to speak to safety as it was discussed, and NOT discussed,format than it appears in the Code of Federal Regulations. He at the convention. To start, and if I do not get a chance totold me he had paid a third party a considerable amount of finishthesethoughtsinthisarticle,Iwillcontinuethemmoney for that safety program. He admitted to me he had in the next article, I want to address some concerns I havenever looked at it and that he did not think anyone in his withtheSHARPSafetyRecognitionProgram.AsfarasIcompany had done so either. Yes, he was cited for not having know, MRCA is one of only two roofing industry contractorsa safety program, but the more important point was that it associations that offer the opportunity to their members todemonstrated a high level of complacency when it came to have their safety programs graded anonymously. This is donesafety. It was definitely not at the top of his list of company with regards to compliance with OSHA standards, as well asvalues or prioritiesI wonder if it was even on the list. from a common-sense safety perspective. They then receive aHow important is safety to you? How important is the detailed letter analyzing the parts of their program that havesafetyandwell-beingofyouremployeestoyou?Canyou been reviewed. honestly say that you do EVERYTHING you need to do, and ForthoseofyouwhoaremembersoftheMRCA,butshould be doing, to ensure that none of your employees get not involved in any of the MRCA programs; we do have ainjured while he/she is working for you? The first step on safetyrecognitionprogram.Itcanprovideyouwiththeyour journey to start putting safety at the TOP of your list of opportunitytohaveyoursafetyprogramreviewedandpriorities for your company is to take a good long look at your critiquedbyanon-biasedappraiser(me).Wereviewyoursafety program. Take a copy of your safety program home response to eight questions that address important parts ofwith you next weekend and, instead of watching the football your safety program. Yes, you are required by OSHA to have agame on Saturday or Sunday afternoon, sit down with your written safety program, to do safety training, and to enforceprogram.Takeapadofpaperandgiveyourprograman safety on all of your worksites. This includes your office andhonest review. If you do not feel that you have the knowledge warehouseareas.Sinceyouarerequiredtohaveasafetytolookatyourprogramcriticallyfromacommon-sense program, why not make it the best it can be? MRCA is givingsafety and OSHA compliance standpoint, take the next step you that opportunity through our SHARP Safety Recognitionand take advantage of the services offered by MRCA, your Program. Our intention is to rotate some of the questionstrade association. If nothing else, start participating in the that are asked each year so that over a period of a few years,SHARPSafetyRecognitionProgramin2019.Therewere allofthecriticalcomponentsofyoursafetyprogramwilltwenty-three participants this year that received a detailed have been evaluated. analysis of their responses to the safety questions that were IhavealwayshearditsaidthatMRCAmemberstakeasked and then reviewed. It is not the level of the award that safety seriously. Yet, I would bet that if I asked each memberis really important; it is more about learning to be confident privately about their safety program, less than twenty-fiveaboutthestrengthsandweaknessesofeachpartofyour percent would have a safety program that is truly effective.safetyprogram.Attheendoftheday,thesafetyofyour Yes, you have a safety program, but DO YOU, the companyemployees is your responsibility.owner or president, have ANY idea of what is in it? Do youNow, I want to digress from the SHARP Safety Recognition have any knowledge of whether what is in it is correct, and/ Program topic. I feel that I need to take a few minutes to or complaint, with OSHA standards? Do you know whetherdiscuss an interpretation OSHA issued on October 11th. At it is being effectively communicated to your employees and,the Omaha Conference we provided a handout with a copy 8 www.mrca.orgMidwest Roofer'