All of our occupational health programs are perfect, right?  We have OSHA Standards to follow, policies written and Standards of Practice (SOPs) in place, and everyone is doing what they are supposed to, right? Or, are they?

Be sure to always double and triple check your processes.

Working on a contractual basis onsite at an up and running large pharmaceutical site for a few months, I recently identified a gap in their hearing protection program. Upon conducting annual hearing screenings and audiograms, many employees did not know how to properly insert their hearing protection.  A great number of employees at this facility wear disposable ear plugs, and I asked each one of them, “How long do you hold those in place before they fully expand?”  Not one employee had the correct answer.  After a few months, I asked Safety Services, “Who provides initial training to the employees on their hearing protection?”  One of the Safety Services personnel brought me the appropriate documentation where he pointed to the section that states the nurse performs initial training to coincide with the employees’ initial audiogram.  The Safety Services member’s jaw dropped when contradicted the documentation by saying, “They have their initial audiogram completed when they have their pre-placement physical completed at urgent care.  I don’t see them for their audiogram until they have been here for a year.”

As an Occupational Health Consultant, I knew to ask the right questions of the right people.

For every process you have, make sure that what you have written matches what you are actually doing.  It does not do anyone any good to have a perfect plan written on paper, if it is not what you are executing. Know that whenever you have even a small change in your process, it is imperative the process be double or triple checked for accuracy.  It may be in your best interest to have someone other than the individuals writing and executing the SOPs check each step of the way, making sure all of the “i’s” are dotted and the “t’s” are crossed.  Ensure they ask the right questions, and actively “walk” thru each of the steps.

If you have any questions regarding written programs and their execution, please do not hesitate to contact me at (919) 459-5275 or