Safe + Sound Week

From natural disasters, like flooding and wildfires, to civil unrest, pandemics, and cybersecurity threats, the need for a robust and adaptable health and safety Emergency Action Plan (EAP) has never been greater. A well-developed EAP not only protects lives, but it can also help minimize damage, promote operational continuity, and reinforce a culture of preparedness.

Core Components of an Effective EAP

In 29 CFR 1910.38, the Occupational Safety and Health Administration (OSHA) requires that facilities develop a written EAP that includes several defined components to address safety and health concerns in emergency situations. At its foundation, an EAP should clearly outline roles and responsibilities, communication procedures, evacuation and shelter-in-place protocols, resource availability, and recovery strategies.

To be truly effective, the EAP must be:

• Risk-Based – Tailored to the specific hazards facing your location, industry, and workforce.
• Accessible – Easily understood and available to all employees, including translations and alternate formats if needed.
• Tested – Regularly drilled and evaluated to identify weaknesses or confusion in execution.
• Integrated – Coordinated with local emergency services, neighboring facilities, and contractors, as well as with other facility emergency plans (e.g., environmental, food safety, security, transportation, etc.).
• Continuously Updated – Adjusted based on lessons learned from incidents, drills, and changing threat landscapes.

Overlooked Elements

Beyond the foundational components that are required in any EAP, there are a number of critical, yet often overlooked, elements that can make the difference between a successful response and a chaotic one:

• Individuals with Special Needs: Plans must account for employees and visitors with disabilities or access and functional needs. This includes evacuation assistance, accessible communication methods (e.g., visual alarms or sign language interpreters), and accessible shelter areas. Failing to provide this support not only increases risk but may also violate regulatory requirements.
• Communication Failures: During a crisis, cell towers can fail, power can go out, and standard communication tools may be rendered useless. Incorporate redundant systems such as two-way radios, satellite phones, or even predetermined physical meeting points to maintain communication under stress.
• Human Behavior and Psychological Impacts: Emergencies can trigger fear, stress, and sometimes panic. An effective plan anticipates psychological responses and includes measures to address those impacts, such as assigning calm leaders, training staff in basic psychological first aid, and having procedures to manage noncompliance or emotional breakdowns during an event.
• Non-Standard Employees: Temporary workers, contractors, and visitors are often left out of training and drills. The EAP should identify how these groups will be informed, guided, and accounted for in the event of an evacuation or shelter-in-place order.
• Blocks and Alternative Routes: Roadways may be blocked by fallen debris, emergency vehicles, or civil disruptions. Pre-identify multiple evacuation routes and practice using them. Update maps regularly and train all personnel on what to do if their primary route is compromised.
• Impact of Weather: An evacuation that works on a sunny day might fail in a snowstorm or hurricane. Plans must consider the timing, temperature, and weather implications on any response. Stock weather-appropriate supplies and plan indoor shelter options to avoid weather impacts to the extent possible.
• Disinformation or Misinformation: False rumors or misinformation can spread quickly, especially on social media. Designate a trusted spokesperson or internal communication channel for official updates. Train employees to verify information through credible sources and not to act on hearsay.
• Overwhelmed Emergency Services: In large-scale disasters, emergency responders may be delayed or unable to assist. Plans should incorporate tools for self-sufficiency—first aid kits, trained staff, emergency food and water supplies, and basic rescue tools—to buy time until help arrives.

Plan, Prepare, Protect

Emergency preparedness is not a one-time task—it’s an ongoing responsibility that must evolve alongside the world we live in. An EAP created five years ago may not address today’s climate threats, social unrest, or technological vulnerabilities.

Don’t wait for a crisis to expose the gaps and overlooked elements in your EAP. Review and update it regularly to address new and evolving hazards. Engage external support to provide a fresh perspective and new approaches. Conduct ongoing risk assessments, scenario planning, and collaborative reviews. These things will help ensure that your emergency strategy remains relevant and effective and your team is prepared, protected, and ready to respond effectively when every second counts.

KTL will be exhibiting at the American Correctional Association’s 155th Congress of Correction in Denver, CO, August 21-26, 2025. The Congress features a wide array of workshops and sessions focused on cutting-edge topics for correctional facilities. The educational workshops feature the best in the business, passing on critical knowledge and engaging in important discussions, while the expansive exhibit allows attendees to interact with hundreds of companies serving the correctional industry.

Be sure to stop by and visit KTL at Booth #871. We look forward to seeing you at the Congress of Correction!

Safe + Sound Week

Electrical safety issues have been among the top findings in the Occupational Safety and Health Administration (OSHA) compliance audits KTL has conducted over the past year. Many workers are unaware of the potential electrical hazards present in their work environment when completing tasks that involve electricity. As such, they end up working in either unsafe conditions (e.g., poorly maintained/deteriorating equipment) or unsafe work practices (e.g., using conductive tools, not de-energizing prior to work)—or both. The result can be an OSHA finding or worse, including electrocution, electric shocks and burns, injury from exposure to arcing, and fire from faulty electrical equipment or installations.

Electrical Safety Standards

OSHA and National Fire Protection Association (NFPA) electrical safety regulations are complex. OSHA actually has several standards that address electrical safety. The most notable for general industry is 29 CFR 1910 Subpart S, which is broken into sections on design safety standards, safety-related work practices, safety-related maintenance requirements, and safety requirements for special equipment. If you have electrical equipment, at least some of OSHA’s electrical requirements will apply.

NFPA 70E supports the OSHA standard and fills in gaps, particularly related to qualified workers and hazard assessments. NFPA states that an Electrical Safety Program should develop a risk assessment procedure that outlines processes to identify hazards, assess risks, and implement controls before work begins. NFPA 70E is revised every three years.

Common Electrical Hazards

Electrical energy remains one of the most serious health hazards in the workplace, which is why all workers need to understand the dangers of electricity and how to take proper precautions. The following are the most common electrical safety gaps identified in KTL’s safety audits over the past year:

• Misused equipment. If electrical equipment is not used as designed or according to manufacturers’ instructions, safety features are not reliable.
• Damaged or defective electrical equipment is damaged or defective. When electrical panels, power disconnects, or any other electrical equipment in use at the site is not properly maintained, it can fall into disrepair. If electrical equipment is damaged, defective, or missing components, this may cause unintended contact with electrical components and lead to injury.
• Improperly used extension and flexible cords. Cords are subject to damage. Normal wear-and-tear can loosen or expose wires. In addition, employees do not always use the right type of cord for the intended usage and tend to repair and reuse cords that should be retired.
• Lack of ground-fault protection. Daily use of electrical equipment may lead to wear-and-tear (e.g., insulation breaks, short circuits, and exposed wires). Without proper safeguards, deteriorating equipment can create a ground fault that may send electrical current through a worker’s body.
• Missing path to ground. If the power supply to the electrical equipment is not grounded or the path is broken, fault current may travel through a worker’s body.

Creating Your Program

To eliminate these electrical hazards and their associated risks, it is important for any organization with electrical equipment to develop a written Electrical Safety Program, train employees, implement and enforce safe work practices, and regularly verify the Electrical Safety Program’s effectiveness.

Written Electrical Safety Program

A written Electrical Safety Program identifies the possible electrical hazards and outlines the procedures and controls required to effectively eliminate or engineer them out. Development of the Electrical Safety Program should be preceded by an electrical safety hazard assessment that systematically identifies electrical hazards that may cause harm, evaluates how likely and severe the potential harm is, and determines methods to effectively eliminate or control the harm from happening (i.e., hazard controls).

The Electrical Safety Program should consider safety through design, electrical risk management programs, job observations, refresher training, personal protective equipment (PPE) and tools, auditing, and electrical incident investigations.

Employee Training

It is important to understand that electrical training is not a one size fits all. As a part of an effective Electrical Safety Program, organizations should identify the scope of the electrical work—and who is qualified to do it—and then ensure those workers who have not been trained do not do electrical work. OSHA puts workers into two categories: unqualified workers and Qualified Electrical Workers (QEWs).  

• Unqualified workers are those employees who are not trained or permitted to work with live electrical components but may face risk of electric shock (above 50 volts). Unqualified workers must receive training on safety-related work practices that pertain to their job tasks and the inherent hazards of electricity (high voltage, arc flash, lack of guarding, etc.).
• According to OSHA, a QEW is one who has received training in and has demonstrated skills and knowledge in the construction and operation of electric equipment and installations and the hazards involved. Only QEWs are permitted to work on or near energized parts.They must have the skills and techniques to distinguish exposed energized parts from other parts of electric equipment and appropriate training on all electrical safety procedures.

Safe Practices and Conditions

Even with the best Electrical Safety Program possible, if an organization continues to implement unsafe conditions or unsafe work practices, electrical safety accidents will continue. The following list provides best practices for working safely with electrical equipment:

General Electrical Safety Principles

• Always assume that overhead lines and all wires are energized, even if they appear to be insulated.
• Never operate electrical equipment while standing in water.
• Do not use electrical equipment that shocks, smokes, smells, is damaged, or has burn marks.
• Train all workers appropriately.

Power Line Safety

• Contact utilities to identify buried power lines, look for power line indicators, and post warning signs.
• Stay at least 10 feet away from overhead power lines (unqualified workers).
• De-energize and ground lines when working near them.
• Use non-conductive wood or fiberglass ladders when working near power lines.

Tools and Equipment Condition

• Use only equipment that is approved to meet OSHA standards, including double-insulated tools and equipment.
• Visually inspect all electrical equipment prior to use and remove any equipment with frayed cords, cracked casings, missing ground prongs, etc. from service.
• Make sure any altered equipment is compliant.
• Continually audit tools and equipment available for use onsite.

Grounding and Bonding

• Ground all power supply systems, electrical circuits, electrical equipment, and exposed metal parts of equipment.
• In wet/damp locations, ensure electrical circuits or receptacles are equipped with a Ground-Fault Circuit Interrupter (GFCI).
• Use GFCIs on all 120-volt, single-phase, 15- and 20-ampere receptacles.
• Follow manufacturers’ recommended testing procedures for GFCI.
• Frequently inspect electrical systems to ensure the path to ground is continuous.

Cord and Plug Safety

• Use factory-assembled cord sets and 3-wire type extension cords marked with designation codes for hard or extra hard usage.
• Use only cords, connection devices, and fittings that are equipped with strain relief.
• Do not modify cords, repair cords with electrical tape, or use them incorrectly.
• Remove cords from receptacles by pulling on the plugs, not the cords.
• Continually inspect cords used onsite.

Lockout/Tagout (LOTO) and De-energization

• When possible, de-energize electrical circuits before doing any type of work according to proper LOTO procedures.
• Use lockout devices to prevent a circuit from becoming energized.
• Use an AC voltage tester to verify that the electrical power is off.

Verify Effectiveness

It is important to analyze the effectiveness of all electrical safety efforts, including electrical safety hazard assessments, the written Electrical Safety Program, and associated work procedures and equipment. Regular audits and inspections can help ensure work conditions and work practices protect employees and create a culture that understands and promotes the importance of electrical safety.

Building Safe Systems

Electrical safety encompasses many different elements and requires specialized qualifications and expertise to safely manage. As such, bringing in a second set of eyes to review and/or help build the right size Electrical Safety Plan for your facility can be helpful (or even necessary depending on in-house electrical capabilities). Relying on experts with not only electrical capabilities but also overall occupational safety understanding can help ensure you implement practical solutions—from compliance audits to customized electrical safety strategies—that integrate with your corporate Safety Program and operations and make your electrical systems as safe as they are efficient.

Safe + Sound Week

According to the Occupational Safety and Health Administration (OSHA), a hazard is any source of potential damage, harm, or adverse health effects on something or someone. It is a condition, activity, or substance that could lead to injury, illness, or even death if not controlled. For any workplace—regardless of size, industry, location, etc.—it is important to understand and control workplace hazards. This is done by conducting a hazard assessment.

Importance of Hazard Assessments

One of the primary root causes of workplace injuries, illnesses, and incidents is the failure to identify and control potential hazards. A hazard assessment (also known as a risk assessment) is important because it takes a thorough look at the workplace to:

1. Systematically identify those things that may cause harm (i.e., hazards), particularly to people.
2. Determine how likely and severe the potential harm is (i.e., the associated risk).
3. Decide what measures should be in place to effectively eliminate or control the harm from happening (i.e., hazard controls).
4. Create a plan to prioritize hazards associated with a specific activity/task/job and implement identified controls.

Steps to Take

Hazard identification and assessment should include the following steps:

• Collect existing information about workplace hazards. Determine the types of hazards that may be present and who might be exposed. This information can come from sources already available in the workplace (e.g., safety data sheets (SDS), operating manuals, OSHA 300/301 logs, job hazard/safety analyses, safety programs, worker input, etc.) or external sources (e.g., trade associations, labor unions, safety consultants, OSHA, NIOSH, CDC, etc.).
• Inspect the workplace to identify safety and health hazards. The objective is to identify potential hazards and address them before incidents occur. Think about how people work and what practices they follow, how equipment is used, what chemicals are onsite, and what the general condition of the facility is. Generally speaking, workers have the best understanding of the work being done, so they should be engaged in inspections.
  • Workplace incidents and near misses provide a clear indication of where hazards may exist. Look at past incident records to help identify less obvious hazards.
  • Consider employees, contractors, visitors, and members of the public.
  • Workstations, processes, operations, equipment, tools—and their related hazards—can all change, so regular inspections should be conducted.
  • Consider physical safety hazards, but also identify workers’ exposure to health hazards, including chemical, physical, biological, and ergonomic hazards.
  • Emergencies and non-routine situations present different hazards to manage. Identify foreseeable emergency situations and non-routine tasks and then develop procedures for responding appropriately and safely to potential hazards.
  • Use checklists to help ensure the major categories of hazards are addressed (e.g., general housekeeping; slips, trips, and falls; electrical; equipment operation and maintenance; fire protection; work organization and process flow; work practices; ergonomics; emergency procedures).
• Assess the associated risk of identified hazards. Think about the types of incidents that could result from exposure to those hazards. Consider the severity of potential outcomes, likelihood that the event will occur, and the number of workers who might be exposed (i.e., the overall risk). How likely it is that someone could be harmed and how serious it could be? Who might be harmed and how?
• Rank your risks. Assigning priority to hazards based on their risk creates a ranking that identifies which hazards are the most serious and should be addressed first. Ranking risks should consider the probability of exposure and the potential severity of an incident. It requires knowledge of workplace activities, urgency of situations, and objective judgement.
• Identify control options. Risk can be reduced/eliminated by controlling or eliminating the hazard or reducing employees’ exposure to the hazard.  
  • Review external sources and investigate control measures used at other workplaces to identify options.
  • Get input from workers who may be able to suggest/evaluate solutions based on their knowledge of the facility, equipment, and work processes.
  • Select controls that are the most feasible, effective, and permanent using the Hierarchy of Controls, which emphasizes engineering solutions first, followed by safe work practices, administrative controls, and then personal protective equipment (PPE).
  • Avoid selecting controls that may introduce a new hazard; discuss options with workers to ensure their feasibility.
• Develop a Hazard Control Plan. The Plan should describe how the controls will be implemented. What are you already doing to control the risks? What further action is required? Who is responsible for implementing the control? What is the timeline?
  • Address the serious hazards first. While interim controls may be necessary, the ultimate goal is to ensure effective long-term control of hazards.
  • Determine whether you can get rid of the hazard altogether. If not, identify what can be done to control the risk so harm is unlikely. This might include redesigning the job; replacing materials, machinery, or processes; reorganizing work; implementing new practices to work safely; or providing PPE.
  • Select additional controls to protect workers during non-routine operations and emergencies.
  • Assign responsibility and deadlines, conduct drills, track progress, and verify the effectiveness of controls once they are installed.
• Implement selected controls in the workplace. Implement measures according to the risk ranking priorities established in the Hazard Control Plan on a “worst-first” basis. Eliminate or control serious hazards as quickly as possible using interim controls, as necessary, while developing longer term solutions. In addition, promptly implement any easy and inexpensive solutions regardless of risk level.
• Follow-up to confirm that controls are effective. Monitor and track progress in implementing controls.
  • Conduct regular inspections and preventive maintenance to confirm controls are operating as intended and still effective, particularly when there are changes to the workplace that could introduce new risks (e.g., staff, processes, substances, equipment).
  • Record your findings so you can track and verify results.
  • Communicate the results. Workers must be aware of every hazard associated with their job and the controls in place to protect them.

Part of the Plan

Hazard assessments are an integral part of a Health and Safety Management Plan. They help organizations to evaluate hazards and then minimize the level of their risk by implementing control measures to prevent injuries and illnesses, meet legal requirements, and create an overall safer and healthier workplace. Employees should be engaged in the process, as they are generally the most familiar with workplace practices. An external party can offer additional perspective, experience, and fresh eyes in answering the following questions:

• What are the potential hazards?
  • What can happen and under what circumstances?
  • What are the possible consequences and risks of those hazards?
• How risky are the possible hazards and associated consequences?
  • How likely are they to occur?
  • How severe?
  • Who will they impact?
• How can we control or eliminate our hazards to reduce risks?
• Are our efforts successful?
  • Have we achieved an adequate level of risk reduction?
  • Is further action required?

According to the Occupational Safety and Health Administration (OSHA), safe workplaces are sound businesses. Every workplace should have a safety and health program that includes management leadership, worker participation, and a systematic approach to finding and fixing hazards. This is what it means to be Safe + Sound.

Safe + Sound Week

OSHA’s Safe + Sound program is a year-round campaign to encourage every workplace to develop and implement a safety and health program. During one week every August (August 11-17, 2025), OSHA promotes Safe + Sound Week as a nationwide event to recognize the successes of workplace health and safety programs and offer information and ideas on how to keep America’s workers safe. This year’s Safe + Sound Week focuses on emergency preparedness and response.

Participating in Safe + Sound Week can help companies get their safety and health program started, energize an existing program, or recognize company and individual employee safety and health accomplishments. It is an ideal time to reflect on and recognize the efforts you have made to improve workplace safety and health throughout the year and to focus in on areas of improvement going forward.

KTL’s Series on Investing in Safety

Throughout OSHA’s Safe + Sound Week this August, KTL will be featuring a series of safety-related articles and posts on our blog and social media (i.e., Facebook, LinkedIn, X), including:

• Hazard assessments
• Electrical safety 
• Emergency response
• Machine guarding
• Strategies for maintaining health and safety compliance.

Watch for these articles! For more information on what your organization can do to participate and promote a strong safety culture, visit the OSHA Safe + Sound Week website.

All types of organizations and operational processes demand a variety of audits and assessments to evaluate compliance with requirements—ranging from government regulations, to industry codes, to management system standards (e.g., ISO, GFSI), to internal obligations. Audits and assessments capture regulatory compliance status, management system conformance, supplier compliance, adequacy of internal controls, potential risks, and best practices.

Internal audits help identify problems so corrective/preventive actions can be put into place and then sustained and improved prior to third-party certification/compliance audits. Internal audits and assessments also help companies with continuous improvement initiatives.

Understanding the Internal Audit Process

Many organizations conduct internal audits with their own staff to assess conformance and identify opportunities for improvement. For companies large enough to have a dedicated internal audit team (with have no ties to the processes they audit), this may make perfect sense. However, it can take significant resources—time, personnel, money—to conduct all internal audits with internal resources.

It is easy to underestimate what goes into a successful audit and assume that it is more efficient and cost-effective to use internal resources. But that often isn’t the case. Let’s consider what an internal audit entails.

Pre-Audit Preparation

• Research: Auditors must understand the standard they are assessing against (i.e., regulatory, management systems, internal, industry). Effective auditors will also understand industry best practices; related local, state, and/or country-based requirements; processing norms for new product areas; etc. that can impact operational compliance and risks.
• Logistics: Logistics includes coordinating with the facility(ies) to schedule the audit and time with applicable personnel for interviews and, if travel is required, researching/booking flights, booking hotels, arranging for car transportation, etc.
• Document Review: Prior to the onsite audit, auditors should review available documentation (e.g., procedures, policies, programs). This will better inform and guide them on where they should dig more deeply during the audit, as well as help them create effective audit protocol (see below). Pre-audit document review also allows the onsite portion of the audit to remain focused on observing operations, interviewing workers, and verifying physical requirements are being met.
• Audit Protocol/Template: Auditors need to take the time to develop protocol/questions for conducting the audit, as well as standardized reporting templates, before the site visit. A standard protocol will make conducting multiple audits more efficient. Consistent protocols and templates also add value by allowing for direct year-over-year and site-to-site comparisons.

Onsite Audit

• Technical Knowledge: To efficiently conduct an audit, auditors must have a thorough understanding of the standard they are assessing against. In many cases, auditors are asked to juggle multiple areas of focus at once. For example, in a foods facility, the auditor may simultaneously evaluate Food and Drug Administration (FDA), U.S. Department of Agriculture (USDA), Global Food Safety Initiative (GFSI), and facility-specific procedure requirements. For an environmental, health, and safety (EHS) audit, the auditor may simultaneously assess Environmental Protection Agency (EPA), Occupational Safety and Health Administration (OSHA), state agency, and facility-specific requirements. Deep technical knowledge of all the related standards and codes helps to ensure a thorough audit.
• Audit Tools: Having the right tool for the job can make audits significantly more efficient. This includes the audit protocol and templates developed as part of pre-audit preparation, as well as audit tools that may be used to conduct and manage audits more efficiently and effectively.
• Audit Management: Auditors are responsible for building a relationship of trust and openness with the facility quickly, while still maintaining control of the audit. This can be a challenge for internal auditors when interviewing colleagues and assessing internal systems.

Post-Audit Follow-up

• Report: Auditors need to synthesize observations from the audit to create a report that concisely conveys all pertinent information, including nonconformances with the defined standard(s). Auditors provide additional value when they can leverage their industry experience to prioritize findings and identify opportunities for improvement and best practices. Reports are most valuable when finalized within a few weeks of the site visit when information is fresh to facility staff.
• Corrective Actions: After an internal audit, facility staff will inevitably have questions regarding findings and what to do next. Auditors can provide valuable support by offering recommendations, building corrective action plans, and supplying technical guidance.

Many organizations do not have dedicated internal auditors—rather, internal auditing is an “add-on” responsibility—so time spent completing these internal audit activities takes time away from other business responsibilities. This often results in a post-audit period where the internal auditor has significant catchup to complete other work that has been put on the backburner while conducting the internal audit.

Value of a Second-Party Auditor

A second-party auditor can provide an objective assessment of overall compliance status and, in many cases, do it more efficiently than organizations are able to do with their own resources. A second-party auditor has the time required to conduct the audit, travel, review documents, and create a report. Beyond that, a second-party auditor also has audit tools and templates to create efficiencies when conducting the audit and reporting, can consolidate audit trips, and can spend dedicated time completing all audit activities as efficiently as possible without needing to factor in other business responsibilities.

Beyond saving significant resources, using a second party to conduct audits provides significant business value and additional return on investment:

• Objectivity: Enlisting a qualified outside firm to conduct an audit provides a fresh set of unbiased eyes to assess aspects of your program internal staff may not consider or see. Second-party auditors offer broad perspective and knowledge of best management practices from conducting audits across industries and standards. They maintain ongoing, up-to-date awareness of current and pending regulatory requirements that the organization should consider.
• Customizable: The audits themselves can be customized to fit the needs and goals of the organization. A second-party auditor can provide more direct coverage to evaluate specific program effectiveness and allow for a more focused understanding of existing strengths and improvement areas. Whether there is a desire to prepare for unannounced regulatory agency visits, review plans and programs, assess supplier compliance, or even verify applicability, second-party audits can be built to address the organization’s identified concerns and help manage risks.
• Effective Tools: Second-party auditors often bring effective audit tools to help conduct and manage audits. These tools capture regulatory compliance status and certification system conformance more efficiently, track audit progress/completion status by subject, and generate reports that can be used by management to inform decision making. 
• Efficiency: Audits performed internally can take resources away from normal business operations not only when conducting the audit, but also when catching up on daily responsibilities and work that is set aside during the audit. Second-party auditors work with the resources allocated to them to conduct an audit in a timely manner that does not negatively impact business functions. These audits minimize the overall disruption in business compared to internal audits.
• Validation: Second-party auditors validate existing programs and identify areas where best practices can be implemented to further protect the company. They assist in identifying and prioritizing issues before they become violations—focusing on implementing and closing corrective actions. They also provide data and reports that can be shared internally with employees to improve performance or externally with communities or customers to bolster the company’s image.  
• Consistency: Using the same second-party auditor to conduct your audits creates consistency across locations and over time. This allows the organization to establish a benchmark for performance that can be used to help ensure continuous improvement throughout the organization and its supply chain.

Second-party audits are not just about checking boxes—they are about building stronger partnerships, spotting issues early, and keeping your business running smoothly. Don’t wait for nonconformances to catch you off guard. Implementing second-party audits isn’t just a compliance tool, it is a strategic advantage.

The Occupational Safety and Health Administration (OSHA) uses inspections to help ensure employers provide safe and healthy workplaces. In April 1999, OSHA implemented its first nationwide Site-Specific Targeting (SST) plan to conduct comprehensive programmed inspections in non-construction worksites with 20 or more employees. The SST inspection program has been renewed and updated since that time, and on May 20, 2025, OSHA issued the most recent directive for its SST inspection program. This new version is more narrowly focused, prioritizing programmed inspections at establishments with high or upward-trending injury and illness rates, as well as those that failed to submit required information.

Key Changes

The SST program uses injury and illness data that employers submit under 29 CFR 1904.41 through OSHA Form 300A. The new SST directive was updated to rely on data from calendar year (CY) 2023 versus CY 2021, reflecting OSHA’s continued efforts to allocate enforcement resources based on the most recent injury and illness data. OSHA then uses this data to target and identify facilities for a potential SST inspection, as follows:

• High-rate establishments: Facilities with elevated Days Away, Restricted, or Transferred (DART) rates for CY 2023. Importantly, OSHA will set one DART rate of manufacturing and a different DART rate for non-manufacturing to provide for equal targeting from both groups.
• Upward-trending establishments: Facilities with rates at or above twice the private sector national average in CY 2022 that have continued to trend upward annually from CY 2021-2023.
• Low-rate establishments: Those with low DART rates. Low-rate facilities will be randomly selected for inspection to verify the reliability of Form 300A data.
• Non-responders: Facilities that failed to submit CY 2023 Form 300A data, as required. A random sample of non-responders will be inspected to discourage employers from not reporting.

What’s Involved

Based on data collected and the above criteria, OSHA Area Offices (AOs) select facilities to target for planned SST inspections. The SST inspections are comprehensive in scope and may be expanded with justification (e.g., including health hazards based on prior inspection history in industry classification).

During the SST inspection, the Certified Safety and Health Official (CSHO) will do the following:

• Review data. The CSHO will review available OSHA 300 Logs, Form 300A summaries, and 301 Incident Reports for CY 2021, 2022, and 2023.
• Conduct a facility walkthrough. During the walkthrough, the CSHO will evaluate potential hazards in all areas of the workplace; however, the focus will largely be on those areas where the facility has had documented injuries and illnesses.
• Evaluate employee exposures. The CSHO will pay particular attention to hazards observed during the walkthrough, discussed in employee interviews, and/or identified on OSHA 300 Logs and 301 Incident Reports.
• Assess the safety and health management system. The SST inspection will focus on whether the management system is adequate to identify and address the elevated injury and illness rates.
• Conduct a closing conference. The CSHO will discuss with the employer identified hazards, gaps in reporting practices, and deficiencies in the safety and health management system during the closing conference.

What You Can Do

The updated SST inspection program update reflects OSHA’s ongoing commitment to data-driven enforcement and targeted inspections in general industry. Correspondingly, accurate data is critical. Facilities must have their OSHA recordkeeping and reporting practices in check. Not only should records be verified as accurate and complete, but each accident should have a documented corrective action. This information should be checked, and any additional actions should be made to fully comply with Occupational Safety and Health (OSH) Act requirements.

But beyond recordkeeping and reporting, facilities can take steps to avoid an SST inspection altogether by making sure they have the processes, programs, and systems in place—and documented—to protect employees’ safety and health:

• Develop comprehensive safety programs and a robust safety management system. A compliance management information system can provide a centralized location to track and manage all safety-related information (e.g., policies, procedures, and practices) to not only help ensure going compliance but to also provide the documentation required should an inspection occur.  
• Regularly assess the level of existing OSHA programs against compliance issues and potential accidents. Identify what may need to change in the facility’s OSHA compliance programs and practices to ensure their effectiveness and then implement and document appropriate corrective actions.
• Maintain robust occupational health and safety and incident. Information technology (IT) tools, such as KTL’s OSHA 300 Power App, with its comprehensive intake form tailored to OSHA 300 and OSHA 300A requirements, make it easier to collect, search, and analyze data—and maintain OSHA compliance. Using a digital forms further helps ensure no crucial data points are missed and makes it easy to filter, search, and analyze records and data to offer deeper insights into safety performance.
• Understand what to expect from an OSHA inspection. Educate staff on the process a CSHO will follow and make sure team members understand their roles in the inspection. Prepare staff to respond appropriately to the CSHO’s questions and, importantly, make sure they know how to locate requested documentation.
• Train employees. All employees should receive ongoing training to fully understand and follow safety processes and procedures. Training should focus on worker knowledge and understanding their responsibilities to comply with identified requirements.

As discussed in KTL’s recent EHS: Top Trends for 2025 article, there are a number of anticipated challenges and opportunities in environmental, health, and safety (EHS) for 2025—some ongoing and some just gaining traction with impacts yet to be known, particularly with the change in Administration just taking hold. Regardless, the importance of investing in a strong health and safety program cannot be underestimated. Here are five tips to help start the year strong in health and safety.

1. Plan for Consistency. With so many changes happening in the world at such a rapid-fire pace, consistency creates a predictable environment for employees to maintain positive health and safety practices. Consistency in both action and communication is equally important in the health and safety world. Inconsistent expectations and actions lead to inconsistent behaviors. Ambiguity in messaging and instructions can further cause health and safety hazards.

Keep it simple and consistently reinforce the same message to elicit consistent safety performance. As some examples:

• Always use the right tool for the job.
• Stop work when needed to address hazards.
• Communicate with other personnel about hazards.
• Always wear the proper personal protective equipment (PPE) for each task.

2. Focus on Continuous Small Improvements. Continuous improvement does not mean erratic change. Change should be sustainable, and that happens best when it is introduced and implemented incrementally. Small changes can lead to big differences; it just requires a plan.  Identify the big goal, and then define those small steps needed to reach it. Thinking big but acting small can help create buy-in across the organization, consume fewer resources, and create small “wins” more quickly to drive momentum toward reaching the big goal.

3. Prioritize Communication in All Forms. When it comes to the characteristics of an excellent safety culture, communication is at the top. It is vital that all levels of management (i.e., senior, middle, supervisory) communicate their commitment to safety clearly to workers. It is equally important that workers feel empowered to discuss their safety concerns. Having a safety culture where workers do not feel like they can speak up at work when it comes to their safety can present significant threats to workers and the overall well-being of the company. 

• Use a variety of communication channels (e.g., one-on-one conversations, regular safety briefings, written materials, visual aids) to improve worker understanding.
• Practice active listening; communication goes two ways!
• Be clear, concise, and consistent in your messaging (see #1 above).

4. Incorporate Leadership. In its Recommended Practices for Safety and Health Programs, the Occupational Safety and Health Administration (OSHA) outlines best practices for implementing and maintaining a health and safety program. Management leadership is a core element. According to the guide, management provides the leadership, vision, and resources needed to implement an effective health and safety program. Management can exhibit this in several ways:

• Demonstrate a commitment to continuously improving workplace health and safety, including eliminating hazards and protecting workers.
• Make safety and health a core organizational value with associated health and safety goals and objectives.
• Establish program expectations and responsibilities that engage employees.
• Provide adequate resources and support for the program
• Set a good example when it comes to prioritizing health and safety.
• Communicate regularly with workers about the importance of workplace health and safety.

5. Encourage Worker Participation. Worker participation is another of OSHA’s core elements of workplace health and safety in its Recommended Practices for Safety and Health Programs. Engaging workers at all levels in establishing, implementing, evaluating, and improving health and safety in the workplace creates buy-in. It is important that organizations encourage workers to report health and safety concerns and promote a psychologically safe environment. Organizations should also work to actively engage employees in other health and safety initiatives, such as conducting hazard assessments, developing policies, serving on safety committees, leading toolbox talks, and more.

All of these tips come down to one thing—protecting employee health and safety. Regardless of external factors (e.g., regulatory uncertainty, supplier requirements, consumer demands, financial incentives, etc.), protecting employees should always be a top priority, and these five tips can help ensure you start the year strong.

Every year, we see a number of environmental, health, and safety (EHS) trends rise to the surface that have the potential to impact many industries. As we enter 2025, some challenges and opportunities in EHS remain ongoing; some are just gaining traction with impacts yet to be known, particularly with a change in Administration just taking hold. Here are some of the top EHS trends KTL is keeping watch on in 2025…

Regulatory Landscape

In 2022, the Environmental Protection Agency (EPA) published its FY 2022-2026 EPA Strategic Plan to communicate the Agency’s vision, priorities, and strategies. Specifically, the Plan includes targeted objectives and outcomes in the areas of climate change; environmental justice; compliance enforcement; clean land, air, and water; and chemical safety. The Occupational Safety and Health Administration’s (OSHA’s) focus centers on National Emphasis Programs (NEPs) for 2025 related to combustible dust, fall protection/prevention, heat, silica crystalline, and warehousing and distribution center operations, as well as many regional directives.

With a new Administration taking office in January, a big unknown of the coming four years is how the EHS regulatory landscape will change. There is speculation regarding plans to reorganize the EPA and establish “pause and review” teams to assess major rules, guidance materials, grants, legal settlements, budgets, etc. How this will translate into regulatory action remains to be seen.

Update: According to InsideEPA.com, acting EPA Administrator James Payne issued a directive on January 24, 2025, ordering all EPA staff to stop all communications with external parties pending further instruction. Exemptions will allow EPA staff to continue to communicate with state and federal agencies, provided they do not discuss enforcement matters; talk to relevant partieis to facilitate imports; and continue conducting inspections. It is unclear at this time how long the directive will remain in place.

Mental Health

Companies are increasingly recognizing that traditional safety programs must evolve to prioritize mental health as much as physical health—from mental health days to employee assistance programs, to stress management training, to flexible work hours. Correspondingly, psychological safety is becoming a critical concept for building effective teams and encouraging workplace innovation and success. A psychologically safe culture allows employees to take reasonable risks in a safe environment without negative interpersonal consequences.

A related concept is safety culture, which is concerned with many cognitive aspects of safety, like norms, perceptions, beliefs, and values. Emphasizing mental health as part of the organization’s safety culture may become a priority for mature organizations. As the concept of total worker health continues to expand, the focus on mental health is also likely to be reinforced by new regulations and standards regarding psychological safety in the workplace.

Sustainability and Climate Change

Environmental, Social, and Governance (ESG) initiatives have dominated many corporate agendas for the past several years, particularly with Europe and Canada advancing standards related to sustainability and climate change data reporting and ISO’s recent Climate Change Amendments. Many organizations have worked to significantly improve their data collection efforts and have integrated climate change management and circular economy principles into their sustainability strategies.

The change in Administration may increase scrutiny regarding the value of these ESG initiatives. We have already seen the Securities and Exchange Commission’s (SEC) March 2024 Climate-Related Disclosures Rule stayed due to multiple petitions and lawsuits. This may be a sign of things to come. Many companies have invested in their ESG efforts and will continue to do so, but 2025 may present an opportunity to reassess and streamline initiatives to ensure they are practical and upholding sustainability goals, while also contributing value to the company.

PFAS

Per- and polyfluoroalkyl substances (PFAS) became a focal point for EPA in 2021 with the publication of its PFAS Strategic Roadmap, which committed to addressing concerns related to PFAS exposure. Actions have included improving reporting on PFAS, as well as adding seven additional PFAS to the Toxics Release Inventory (TRI) in January 2024 and an additional nine in January 2025. In April 2024, EPA announced three more notable actions, including introducing the first-ever national drinking water standards and designating perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) as “hazardous substances” under Superfund. In addition, the updated Interim Guidance on the Destruction and Disposal of PFAS and Materials Containing PFAS will require entities to report releases of these “forever pollutants” that exceed threshold quantities. 

Beyond federal regulations, many states are introducing policies related to PFAS, including monitoring and testing for PFAS in water and sewage sludge and banning PFAS in food packaging, clothing, and other consumer products. Organizations need to address PFAS in their operations, products, supply chains, and waste streams; stay informed about ongoing PFAS regulatory developments; and adjust compliance programs and operational practices, as needed.

Personal Protective Equipment (PPE)

Properly fitting PPE is essential for workers to complete their tasks safely. If PPE is not correctly fitted to the body, it can cause discomfort and increase the risk of workplace accidents and injuries. On December 11, 2024, the Occupational Safety and Health Administration (OSHA) announced its finalized revision to the PPE Standard for Construction, which requires PPE to properly fit any construction worker who needs it, including women and physically smaller or larger workers.

Employers must ensure that every employee not only has the right PPE, but that it also fits. Fit testing may identify the need for PPE alternatives to meet the anthropometric needs of all workers. Importantly, employees must be trained and empowered to speak up if PPE does not fit appropriately to ensure their safety.

Technology/AI

Artificial intelligence (AI) and machine learning technologies have the capacity to significantly alter how companies manage their EHS programs. While still not fully mature, these technologies are becoming more sophisticated. As AI evolves and becomes more generally accepted, more companies are likely to start adopting it to automate routine compliance tasks, conduct EHS assessments, perform training simulations, predict potential safety incidents, monitor workplace conditions in real-time, and more.

While the efficiencies and other benefits of technology solutions are many, the increased reliance on AI and machine learning will require increased oversight and management. In particular, companies will need to determine where automation is appropriate and where the human factor is still required. Not all processes lend themselves to AI. It will also be imperative to consider stronger data privacy protocols to ensure the security of the company.

Others to Watch

• OSHA Reporting: On January 1, 2024, the Department of Labor’s (DOL’s) final rule requiring employers in designated high-hazard industries to electronically submit injury and illness information to OSHA took effect. KTL inspections routinely find errors and omissions in OSHA recordkeeping. Effective solutions, particularly areas where hard copies can be replaced by digital forms, are needed.
• Hazard Communication Standard: The final Hazard Communication Standard took effect on July 19, 2024, implementing the first major updates since 2012. The first compliance date requires chemical manufacturers, importers, and distributors to update labels and Safety Data Sheets (SDSs) for chemical substances by July 19, 2026.
• Lead Levels: In January 2024, the EPA reduced the acceptable amount of lead in soil for residential exposure, stating that no level of lead is acceptable. These reduced levels may soon be translated into commercial exposures. 
• One Health: Both the Society of Environmental Toxicology and Chemistry (SETAC) and Society of Toxicology (SOT) have adopted One Health initiatives as an integrated, unifying approach that aims to sustainably balance and optimize the health of people, animals, and ecosystems (SOT). The idea is to look at the health of our environment and all aspects of our environment as a whole and not one component at a time. This idea is being translated into health impact assessments. 
• Pesticide/Herbicide Re-evaluation: The EPA has initiated re-evaluations of registered pesticides, herbicides, rodenticides, and fungicides, including the highly publicized Roundup. These reviews are expected to result in a recommendation to focus the use of these chemicals rather than using a general broadcast application. 
• Microplastics: Microplastics have been found in every ecosystem on the planet—in food, beverages, and human and animal tissue. Scientists do not fully understand the impacts of microplastics on human health and aquatic life, and industry is struggling with how to manage them due to their pervasive nature and wide variety of shapes and sizes. Ongoing research in pollution prevention will be forthcoming.

Getting Ahead in 2025

In 2025, organizations will continue to encounter evolving workplace challenges, regulatory adjustments, societal demands, economic pressures, and rapid advancements in technology—some of which can be anticipated, some which remain to be seen. KTL suggests completing the following early in 2025 to prepare for whatever is on the horizon:

• Get senior leadership commitment. Even with the best EHS personnel, the organization and its EHS system will only be as strong as the top leadership and what they prioritize.
• Stay abreast of regulatory developments. Monitor what is going on at the federal (i.e., EPA and OSHA) and state levels, assess your regulatory applicability, and evaluate how any potential regulatory changes over the next year(s) may impact your operations.
• Conduct a comprehensive gap assessment to ensure you are efficiently meeting your EHS requirements (i.e., regulatory, management systems, internal, supply chain). Think critically about how overlapping requirements may apply (e.g., your chemical inventory may uncover requirements for air permitting, waste management, Tier II report, etc.) and how you can integrate systems to improve efficiency and compliance.
• Determine where you can integrate technology solutions into your operations. This could mean stepping into the world of AI and machine learning; it could also mean implementing compliance information management systems to help manage compliance and reporting requirements. Technology advancements can help create significant business efficiencies when used appropriately.
• Seek third-party oversight. Many EHS departments are severely understaffed. Having external experts periodically look inside your company provides an objective view of operations, helps you to prepare for audits, and allows you to implement corrective/preventive actions that ensure compliance. An outside expert can often provide the “big picture” view of what you have vs. what you need; how your plans, programs, and requirements intersect; and how you can best comply with changing requirements.

Look for KTL October 15-17, 2024 at UW-Madison’s 36th Annual Product Liability Conference in Madison, WI. The Conference presents current and emerging product liability prevention practices. KTL will be leading the following session as part of the Conference agenda:

Creating a Safety Culture: Tools and Strategies for Growth
Session 6 | Presenters: Will Brokaw, MS, Consultant, and April Greene, CSP, CHMM, Consultant

Safety culture is the sum total of your organization’s values, beliefs, attitudes, and actions toward safety. It is often referred to as “the way we do things around here” regarding safety. Previous research has identified key attributes or qualities that positive safety cultures share. This presentation will review these key attributes, provide real world examples, and discuss tools and strategies organizations can use to assess and improve their existing safety culture.