On this page · 9 sections
A safety policy may ask people to engage, speak up, pause work and learn. An action plan needs to explain how those commitments become decisions: who responds to a concern, what resources are available, how controls are checked and what happens when a problem remains unresolved.
My original Safety Management System (SMS) Action Plan proposed three starting objectives: safety governance, exposure assessment and daily communication. This revision keeps that structure and strengthens the connection between management decisions and evidence from work. The manuscript is undated; its source file was created September 19, 2020, and last modified September 22, 2020. Those file records do not establish an earlier publication date.
Define what the action plan needs to change
A useful action plan identifies a gap in the work system and the response intended to address it. Start with the work being managed: activities, locations, people, equipment, contractors and important changes. Review available hazard information, worker concerns and earlier actions before deciding which improvements need attention first.
OSHA’s management-leadership guidance recommends assigning responsibilities, setting timeframes and identifying resources for program goals. Use that structure to make each objective actionable. This article develops an implementation approach; it is not a complete safety program, a standards-conformity assessment or a substitute for applicable requirements.
For example, “improve communication” describes a direction. “Resolve unclear responsibility for checking controls when work passes between shifts” identifies a decision the organization can investigate and address. Define the intended change before choosing a meeting, form or training activity.
Connect policy commitments with decision authority
The earlier version proposed safety councils at location, district, territory and executive levels. That arrangement reflects the proposed organization, not a universal requirement. A smaller operation may need fewer layers. The practical question is whether a concern can reach someone with the authority, information and resources to resolve it.
Senior leaders should identify who can authorize resources and resolve conflicts between functions. Operations managers coordinate implementation in the work they manage. Safety specialists support assessment and technical review. Workers contribute knowledge of the task and help evaluate proposed changes. Record the actual responsibilities rather than assuming that a shared commitment makes ownership clear.
A council should produce decisions that can be followed through: what was agreed, who owns the response, what support is needed and when its result will be reviewed. If a local team cannot resolve a concern, define the escalation route. A meeting schedule does not resolve an issue that nobody has authority to change.
Build around three connected objectives
The three objectives below are a starting structure adapted from my paper. Select and expand them according to the actual operation; they do not exhaust the elements of a management system.
| Objective | Question to resolve | Evidence to seek |
|---|---|---|
| Safety governance | Can the people responsible obtain decisions and resources for unresolved concerns? | Named decision owners, escalation records, resource decisions and follow-up. |
| Hazard and exposure assessment | Does the assessment reflect the actual task and the conditions under which protections must work? | Current task information, worker input, appropriate technical assessment and checks of controls. |
| Daily communication | Are changes, interfaces and unresolved concerns understood by the people affected? | Relevant handover information, decisions about changed work and confirmation that concerns reached an owner. |
These objectives interact. A pre-task discussion can reveal a control gap that needs technical assessment. The assessment may identify a resource decision beyond the supervisor’s authority. Governance then determines how the issue is resolved and how the outcome returns to the people doing the work.
Treat the JSA library as a reference for actual work
The original plan proposed a shared Job Safety Analysis library and task-level reviews. A library can preserve useful information, but the presence of a document does not establish that its assumptions match the current equipment, sequence, location or people involved. Confirm what applies and identify what has changed.
Discuss the task with workers, examine relevant conditions and obtain appropriate technical support where needed. Identify the protective function expected from each control and how it will be checked. The hierarchy of controls can inform selection; naming a control in a JSA does not demonstrate that it has been implemented or is effective.
The earlier paper stated too broadly that its assessment process would ensure all safety risks were evaluated. This revision removes that assurance. An assessment can have gaps, and changing work can introduce conditions not covered by the earlier review. See How to Conduct a Job Safety Analysis for a task-based introduction.
Give each action resources, a deadline and a verification plan
Record the concern, intended result, accountable owner, supporting roles, resources, target date and escalation route. Identify any immediate response or interim protection separately from the longer-term improvement. Urgent hazards must be addressed through the workplace’s prompt response arrangements, not deferred until an action-plan meeting.
Before closing the action, decide what evidence could show that the intended result was achieved. OSHA’s hazard-prevention and control guidance recommends assigning responsibility, setting target dates, tracking implementation and planning how effectiveness will be verified. The method must suit the actual hazard and control.
Keep implementation and verification separate in the record. A completed work order, revised procedure or training attendance list documents an activity. Further checks may be needed to establish what changed in the work. The companion article, Employee Safety Suggestions: From Worker Input to Verified Improvements, provides a detailed response process and printable action record.
Use leading and lagging indicators together
An earlier version proposed using leading indicators in place of lagging indicators. This revision changes that recommendation. OSHA’s leading-indicators guidance recommends using leading indicators to support change and lagging indicators to evaluate effectiveness. They answer different questions and should be interpreted with information about exposure, reporting and other changes.
Meeting counts, huddle participation, completed JSAs and action closures can indicate whether planned activities occurred. They do not, by themselves, establish the quality of the activity or the performance of a protective control. Pair each activity measure with a question about what happened in practice.
| Activity measure | Follow-up question |
|---|---|
| Safety council meetings held | Which decisions resolved a resource or coordination gap, and what remains unresolved? |
| Actions marked complete | Which results were verified against the original concern, and which actions need revision? |
| JSA reviews completed | Did the review identify changed conditions or controls that did not match the task? |
| Daily huddles completed | Did people identify an interface or change requiring action, and who responded? |
Define the population, timeframe and evidence behind a percentage. Separate “implemented, awaiting verification” from “verified closed.” Review overdue actions by the significance of the unresolved concern. Neither a high activity count nor a favourable injury-rate trend is sufficient to establish that the whole system is effective.
Worked example: responsibility at a shift handover
The following scenario is illustrative, not a documented field intervention. At a fictional receiving operation, workers report uncertainty about who checks pedestrian and vehicle arrangements after a delivery changes the work layout. Both shifts assume the other has reviewed the change.
The objective is to resolve the responsibility gap and verify that the agreed arrangements function in the relevant conditions. An operations manager owns the response, with affected workers and appropriate technical support. The plan identifies who assesses the changed layout, who authorizes the response, what information passes between shifts and what evidence is needed before the action is closed.
A new handover checklist may be part of the response. Verification asks whether responsibilities are understood and carried out during relevant handovers, whether the required controls are present and whether unresolved conditions trigger the established escalation process. A signed checklist alone does not answer those questions. This example does not specify traffic-control design or authorize work to continue with an unresolved hazard.
Make management review a decision point
Review whether actions were implemented, whether the defined checks support their intended result and whether the work introduced new concerns. Ask affected workers what changed and what remains difficult. OSHA’s program-evaluation guidance recommends worker involvement and checking whether the program operates as intended and controls identified hazards.
When evidence is incomplete, identify the missing assessment, resources or authority and assign the next decision. When a change does not work as intended, revise the response. Record the reasons and communicate them back to the people affected. The review should change the plan when necessary, rather than simply reproduce its dashboard.
This article contributes a revised planning structure and questions for testing implementation. It does not report a field trial, validate an indicator set or demonstrate an injury-reduction effect. Start by making the link between policy, resources, action and verification visible, then use evidence from the actual work to improve that link.
References and source record
- Occupational Safety and Health Administration. (n.d.). Management leadership. Recommended Practices for Safety and Health Programs.
- Occupational Safety and Health Administration. (n.d.). Hazard prevention and control. Recommended Practices for Safety and Health Programs.
- Occupational Safety and Health Administration. (n.d.). Leading indicators.
- Occupational Safety and Health Administration. (n.d.). Program evaluation and improvement. Recommended Practices for Safety and Health Programs.