Theatre Design & Technology - Spring 1996 - 54

tant elements of any hazard training progranl
because OSHA expects the employer to have a
way to prove that an employee has received
and understood all the neCeSSal)' training for
working around the hazards related to his/her
job responsibilities. OSHA's Publication #2254
- "Training Requirements in OSHA." does a
good job of describing what you need to do in
order to comply with their training requirements.
Ei\lfORCE SAFETY POLlClES: Be vigilant and
enforce your safety policies anlOng the work
force, and within management as weU. Keep
records of all infractions (including action
taken) and establish some method of rewards
or penalties. The employer must be able to
prove to OSHA that they have diligently and
uniformly enforced their safety policies.
SPECT EQUIPMENT REGULARlY: Inspect
hazardous equipment on a regular basis to
make sure that it hasn't become too dangerous
(look for that ladder with a cracked rung, or
the saw arbor with the stripped nut). Thoroughly document your equipment inspection
program as well as each individual inspection
(dated check-off or sign-off sheets are advisable). These inspections do not have to be cal~
ried out by a supervisor. They can be assigned
to an employee as a part of their regular
weekly, bi-weekly, or monthly duties.
MAKE WRITTEN SAFETY PROGRAM AVAlL!\BLE
TO EMPLOYEES: The complete written safety
program must be made available to each employee, and must be kept on record for possible inspection.

STEP FIVE:

* a current list of hazardous materials on
hruld with accompan~ing material safety data
sheets (kept in an accessible location so that
employees can refer to them whenever they
wish)
* a written hazard communication program 6
* results of mandatol)' monitoring of exposure to other hazards, such as high noise
levels, harmful
light, medical testing mandated in a respiratol)' protection program, etc.
* copies of any notices or citations issued
by OSHA
* employee training progr;un summary
including class outlines, attendance sheets,
ruld test results
* records on equipment and facility inspections and subsequent repairs.
Although tlus seems like a lot of paper
work, the more regularly you do it, the less oppressive it witi become. Moreover, accurate
records can help you identify safety problems
that were overlooked in your earlier hazru'd
assessment process.

WHO IS
RESPONSIBLE?
The FIVE STEPS above can provide a helping
hand to those just starting down the road to
OSHA compliance. However, many people get
tripped up initially by questions about respollsibi/i~)1. OSHA is vel)' clear that tbe elllplo)1er
is the one responsible for ensuring a safe
workplace, (see sidebar, "General Duty
Clause") but deciding which person or group
of people is responsible for implementing and
monitoring OSHA compliance is sometimes
tricky. In cases where subcontractors are involved, it can get complicated.

RECORD KEEPI G
KEEP RECORDS: Record keeping is an essential part of your compliance with health ;U1d
safety struldards. Inspectors often go immediately to your records when they come on site,
since it's there that they can most qUickly assess the adequacy and the effectiveness of your
safety program. Most of these records must be
open for your employees inspection at any
time (except for certain confidel1lial medical
data that may appear on your accident report).
Some of the records that should be kept are:
* OSHA Form 200 accident reporting log
and a copy of all posted OSHA 141 summal)1
statements)
* a list of occupational hazards ;U1d their
locations
52

SPRING

TD&T

THE SAFETY COMMITTEE: The employer, be it
a corporation, a theatre company or a university, is an abstract emity. The strategy most often used to assign a face ruld a nrune to this
abstract entity is to establish a safety committee charged with creating, writing, and implementing policies lU1d procedures. The safety
committee should include a representative of
upper management, all workplace supervisors a health and safety officer or consultant,
and at least one worker from each area. Including representatives from all levels of the
organization is importrull for a number of reasons: hazard identification is easier and more
thorough when both the employees who perform hazardous work tasks and the safety officer who is familiar with safety regulations

work together; changes in work practices and
procedures when worked out together by both
labor and management tend to be more practical, safe, and accepted by the employees; and
active management participation makes it
more likely that practices and policies which
are formulated by the safety committee witi be
implemented through the necessal)1 managerial decisions such as funding, discontinuation
of unsafe operations, changes in equipment
and tooling, changes in work practices, enforcement of the safety policies, etc. One member of the safety comnuttee needs to serve as
the "expert" on the federal regulations. In
larger organizations, this person will often be
a fuU-time safety profeSSional.
ASSUME RESPONSIBILlTY FOR YO R OWN
WORKPLACE: In many large orgrulizations, universities for instance, the overall health and
safety policies and rules don't do a good job of
establislung a safe working em~ronment for
theatre people. nless the theatre workplaces
ruld procedures ruoe subjected to a specific
hazard identification and compliance process
that includes participation by theatre department workers, it is unlikely that all the existing
hazards will be addressed or that theatrical
workplaces will be OSHA compliant.
S iBCOKTRACTORS: Responsibility for OSHA
workplace compliance is especially complicated in situations where subcontracted work
occurs. Let's take the exrunple of a private rigging company lured by an arena to do the rigging for a touring show. Who is expected to
provide the safe workplace for the riggers, the
arena or the rigging company? The answer is
both. The arena must assume overall compliance responSibility for work done on its site
(see 29 CFR I926.I6(a)) even though the rigging company still has primal)1 responsibility
for its employees under the General Duty
Clause. OSHA does, however, allow specific
compli;U1ce responsibilities to be contractually
assigned to one party or the other. For instance, the rigging company in its contract
could assign responsibility to the arena for
proViding adequate fall protection systems
above all rigging beams. On the other hand,
the arena, recognizing it does not have adequate fall protection installed where the riggers must work, could assign responsibility to
the rigging complU1Y for the safety of its own
workers. In this case, the subcontracted
complU1y's only option would be to set a fee
and a time schedule up front which makes it
possible for adequate safety measures to be

Table of Contents for the Digital Edition of Theatre Design & Technology - Spring 1996