HOW TO APPLY THIS INFORMATION TO YOUR COMPANY
This page and those on the AISC web site reached by linking from this page are considered the Safety Pages
of the web site. The information collected and presented on the Safety Pages
of the web site is monitored by a committee of industry professionals with specific experience in the application of current safety standards and accepted safety practices to the fabricated structural steel industry. The information on the Safety Pages
of the web site is presented as an aid to fabricator management in administering safety programs for their individual companies. It is intended to assist in stimulating an atmosphere of safety awareness; and not necessarily for the accuracy or applicability of the information presented to individual workers' exposure to safety risks. This information is necessarily limited in scope and is not intended to be a source of legal advice. Each fabricator that chooses to develop a company safety program remains responsible to determine that all regulatory requirements that apply to the individual company are contained in the company safety program, regardless of whether such requirements may or may not be included in the information provided on this web site or may differ from the circumstances described in this web site .
All examples provided are not necessarily applicable to all steel fabrication facilities. The facilities and practices of each individual company, and the provisions of any proposed company safety program, should be thoroughly audited by a qualified safety professional and qualified legal counsel with particular expertise in employment law and occupational safety and health regulations before that safety program is implemented. The administrator of this web site specifically disclaims any responsibility for the correctness or effectiveness of the information provided as applied to any individual company safety program or for updating any information contained herein subsequent to the date of publication of this Manual.
In particular, fabricator management, its safety professional and its legal counsel should be aware and pay particular attention to the following:
- Any examples utilized that are based on and reflect federal laws may not reflect state laws, which may vary from, or contain provisions in addition to, provisions contained in federal law.
- Fabricators that are subject to collective bargaining agreements must exercise care to assure that any provisions contained in their company's individual safety manual (such as, by way of example and not by way of limitation, the activities of safety committees, safety awards programs, and utilization of safety equipment) comply with the requirements of the company's collective bargaining agreements and/or other employment policies and practices.
- The provisions of any company Safety Manual must comply with applicable state and federal regulations applicable to confidentiality of medical records and information (including ADA and HIPPA) and be consistent with the company's overall records retention policies. Provisions related to employee medical monitoring and surveys must also comply with the ADA and any similar, applicable state law.
- Any information related to personal protective equipment (PPE) must be consistent with general employment policies in company handbooks or in the collective bargaining agreement, if applicable, including policies related to paying for PPE.
- Occupational injury management involves a variety of HR issues under not only OSHA, but also under state worker's compensation statutes, short term disability and long term disability plans, the FMLA, the ADA, HIPPA, ERISA, Title VII and the Age Discrimination in Employment Act, as well as collective bargaining agreements, employment practices and policies in company handbooks or manuals, and a variety of state laws. Accordingly, some companies may choose to administer occupational injury management exclusively through its Human Relations department and omit this subject matter from any safety manual that is distributed to all employees.
- Likewise, some companies may consider drug and alcohol testing and blood borne pathogen policies, as being beyond the scope of a safety manual that is distributed to all employees, and to assign administration of these programs exclusively to the company's HR department.