Looking at Your Club’s Safety Issues from Afar

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One of the pleasures of my job is being invited to spend time behind the scenes at clubs. Normally it is only the staff that does the day-to-day running around behind the scenes at the club and when I am your club, I always enjoy seeing the operations through “my safety eyes.” I am always looking at the facilities from a different perspective; looking at the staff’s approach to their duties; and concurrently savoring the beauty of a club whether it is a newer facility, recently renovation or housed in a century-old building.

Sometimes My Safety Audit Starts Before I Get There
Oftentimes, I ask managers for the club’s OSHA 300 and 300A logs before I arrive on site. The reason for this request is to allow me to look at what injuries have occurred. I normally request copies for the previous five years. The reasons for this request are twofold:

  • First, it ensures the clubs is in compliance with OSHA’s recordkeeping requirement of maintaining and retain the records for the obligatory five years, and
  • I can compile a five-year injury/illness spreadsheet.

Why do I do a five-year compilation? I do so to determine if any trends are evident. Are knife injuries occurring? Are slips, trips and falls happening on the loading dock? Are falls occurring on the back stairway? Are lifting injuries evident when putting clay on the tennis courts? Are training programs needed to prevent future incidents? Are bee stings and/or poison ivy exposures happening on the golf course? (Yes, these two items are OSHA recordables.)

What I Would Tell You To Do to Start Addressing Safety
Look at your past incidents. Unless you are actively monitoring what has happened, you are not likely to prevent something from recurring. Start with your OSHA 300 logs. If you are not doing the logs: start now and backdate them as you do the prior years. Obviously you will need your Worker’s Compensation (WC) loss runs to develop your OSHA 300 logs.

There are times when I also look at your WC loss runs for five years as well as your OSHA 300 logs. Why? Not all items on your OSHA 300 logs are WC issues; for example, providing first aid to an employee is not an OSHA recordable.

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Do You Need a Safety Professional?

In one word – Yes. Safety awareness starts with you searching out what has happened. Learn what has happened at your club and at similar types of clubs. Learning safety the hard way can hurt - whether physically, mentally and/or financially.

I would advise you to start by bringing your insurance company’s loss review person in. Additionally, I would advise you to ask questions, lots of questions – my first question for the loss review person would be asking what knowledge they have working with and/or in private clubs.

Your OSHA 300A Log Is To Be Posted By February 1
Reminder: Your OSHA 300A log – the Summary of Work-Related Injuries and Illnesses is required to be posted in the workplace by February 1 of the year following the year covered by the form and keep it posted until April 30 of that year.

The 300A log is to be signed by the General Manager or a Board member certifying he/she is aware of the incidents on the log. (The office manager/person taking care of the WC issues is not the person to sign the log.)

There may be numerous bulletin boards where the 300A logs are posted (Clubhouse, Ground department, Tennis, Pool, Fitness) depending on what areas of the club are operational and where the employee bulletin boards are.

Some Athletic and City Clubs (classified under Civic and Social Organizations) are exempt from Federal OSHA Recordkeeping requirements for maintaining the OSHA 300/300A logs unless they are asked in writing to do so by OSHA, the Bureau of Labor Statistics (BLS), or a state agency operating under the authority of OSHA or the BLS. All employers, including those partially exempted by reason of company size or industry classification, must report to OSHA any workplace incident that results in a fatality, in-patient hospitalization, amputation or loss of an eye.  

Closing Thought
If OSHA does arrive at your front door one of their first requests will be for your OSHA 300 and 300A logs. You are required to produce these logs within four hours. So I will ask: could you honor this request if OSHA showed up tomorrow?

Achatz PixAlan E. Achatz, CCM, CHE is a former club manager who assists clubs with safety issues  including emergency action planning / plan implementation, crisis management, OSHA compliance and behind the scenes safety audits. Alan has written extensively about safety concerns for clubs. Alan has received the NYS Certified Health and Safety Specialist designation allowing him to help to businesses with significant Worker’s Compensation losses. He may be reached at 716-565-9122 or at www.clubsafetysolutions.com

References: 
 
www.osha.gov
https://www.osha.gov/recordkeeping2014/index.html