Buckaroo Podcast Episode 6: Discover how to Better Manage Risk and Make OSHA an Ally

Find out how to understand and manage risk in your manufacturing facility – make your organization more profitable, agile, and flexible. Discover initial OSHA challenges and hazard assessments for COVID-19. OSHA 3990 - Guidance on Preparing Workplaces for COVID-19.

Guest: Christy J. Jennings, ARM, COHC. President / Senior Safety and Health Consultant at SafeMetrics LLC.

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Transcript

Speaker 1: 0:02

Welcome to the buck room marketing, new media podcast, your resource for B2B marketing for manufacturing in the related industries, you create unrivaled products and services. We tell your story now onto the show.

Speaker 2: 0:18

I'm Deb daily, your host for today's program and co-founder of Buckaroo marketing, new media today's guest Christy Jennings, who is the president and senior safety and health consultant for safe metrics. Hey Kristy, welcome to our show.

Speaker 3: 0:33

Hey, thanks for having me.

Speaker 2: 0:36

So why don't you tell us a little bit about your background and how you got to be where you are?

Speaker 3: 0:42

Sure. So I started out as emotion compliance officer, um, which has really given me the ability to understand how OSHA manages the interpretation of the law. Uh, but then I went from OSHA to an insurance company, which is kind of an unusual jump, right? Not many people do insurance from OSHA, but it gave me a real perspective on how to manage risks and the interpretations that maybe other agencies would use on applying the OSHA standards and the EPA standards. So that was a unique experience. I was there for 15 years, roughly, and then from there I went to, um, consulting. So I gathered all that knowledge that I got from OSHA and the insurance companies, and tried to service others in, in giving them, uh, an understanding and I find side of how to interpret the law, how to manage their business within the aspects of the law and how to reduce risks. So that's kind of, that's kind of my history. I've been doing this for, uh, 25 plus years. I'm not so sure. I would always want to say that, but yes, it's been a while. So I really rely on my experience and wisdom to help clients do what they need to do to get done. Sure.

Speaker 2: 1:56

And I'm sure that's so much more valuable than book knowledge because there's so much you can't learn a book, so you need hands-on practice.

Speaker 3: 2:02

Absolutely. Absolutely. I think, uh, the boots meets the ground is a real valuable asset because not every condition is the same. Right. But you can identify conditions that while I had this client and, uh, this is what they did. So I think that a lot of comes with the wisdom piece. So I guess, uh, I'll take, I'll take the wisdom sometimes. Right. So

Speaker 2: 2:25

What does arm and CMHC stand for?

Speaker 3: 2:29

So arm is an insurance designation is, uh, associate and risk management, which is a broad certificate that identifies the concepts of how you manage risks. Right? You can accept the risks. Um, you can choose not to manage the risk and take the punishments or the corrective actions that come with it. So it identifies the different ways, um, of risk and managing risk it's. Um, again, it's an insurance designation, but it's applicable really along all lines of really what we do. Right. Um, and the other one, I think the business see OHC, which is certified occupational hearing conservationist. So what that is, is it's really more specific to OSHA and how OSHA reviews, audiograms and the need for hearing conservation program. Um, so it's a little bit of a specialty that allows us to do certain things, um, from a certified manner under the hearing conservation programs that OSHA requires. So, okay. Did not know that. Yeah. So

Speaker 2: 3:31

Why don't you tell me about safe metrics and the types of services that you provide?

Speaker 3: 3:38

Okay. So save metrics, uh, is a company that was started back in 2006 and we've evolved into a broadly applicable. We call it a risk management company. So oftentimes there's various types of risks that manufacturers have to really navigate throughout their business day, whether it be OSHA or EPA or, um, the loss of an injured employee. Um, but they all have risks in them. So that's what we try and do is manage that risk on behalf of the client, understanding the aspects of the compliance piece. But also if there's a creativity piece that if we can manage it in a way that makes them manufacturer more profitable, profitable, um, more agile, more malleable, right? Because that's really what you want to be as a manufacturing. You want to be flexible. And so that's what we do is kind of, it's a little bit of science, but it's a little bit of art. So we do, um, OSHA compliance, EPA compliance, which is pretty standard expectations. And then we have, um, we reach out from the risk management aspect and we do claim navigation, which is worker's compensation adjusting, but with a little bit of a creative twist. So, um, that's a unique piece. We have a telephonic nurse on staff within COVID. That was a condition that we thought was very valuable where people would not necessarily need to go to a brick and mortar facility to receive treatment, but they could get oversight on how they were feeling and what they were feeling. Um, and if it would impact a work comp claim and if it was wellness related. So that telephonic nurse piece came into to be a big player, um, during COVID. So it's a lot of items that are risk management related, but those are, those are the key services, um, OSHA, EPA claim navigation. We have, um, online training, classroom training, um, OSHA audits, I mean just the gamut. So really it's considering what the employer is interesting is interested in managing and how we can creatively, make them, have them meet their goals. So

Speaker 2: 5:46

It's not necessarily where you have to do everything. If they already have the training piece in place, you can absolutely. You can, you know, your, your company will go in and fill in the gaps if need be, or provide the full meal deal if necessary.

Speaker 3: 6:01

So you could get it Allah card, if you'd like, or you can get it as a menu of services. And so, you know, really that's the creative piece, the art and the science that goes along with it is understanding the client, understanding a budget, understanding their expectations, how quickly they want to get there. And then having us just sprinkle the salt and pepper on the meal and making it taste a little bit better. So we can be the full meal, or we could just be a side dish or whatever really fits the, um, the client's needs. Um, some of them are job specific. Uh, we just have this specific niche, we just need air monitoring completed, or a response to an OSHA letter, or we could be the, um, uh, like a contractor that works that puzzle piece all the time for the insured. So, um, it really varies, but, uh, yeah, we're flexible. And I think that's part of what makes us a little bit unique. Okay.

Speaker 2: 6:54

Um, so why don't we talk about some of the shared challenges that manufacturers, um, face, cause I know a lot of your clients are manufacturing related, right. Or industries that serve manufacturing. So what types of challenges, uh, are you currently seeing and what are they facing? What are some comments?

Speaker 3: 7:14

Um, I mean, I think the obvious is COVID right, is there's, um, uh, a condition that's not been assessed before, so how do we manage it? So that's, that's quite common, but you could still use those same principles in many other things that manufacturers are being feeling. Um, we're seeing now that people can't get the training done necessarily because either they don't have a comparable staff, um, or you have people that are not always on site because of COVID or changed working conditions. Um, so meeting the compliance elements, uh, are becoming a little bit more difficult. Um, and it's not just because the individuals or the companies are not able, but they've been given just a whole nother, um, set of conditions that they have to manage. So, uh, under the auspices of OSHA, um, COVID has to be managed as a risk, which means you need to have a hazard assessment completed and you need to have a PPE hazard assessment completed, which are all technical terms. But if you have an OSHA compliance visit on site, they're going to ask for these things. So it's not just the CDC response, which is probably the natural response, right. But there is an OSHA response to it. And perhaps social has not been the leading voice in this event. Um, but they are a voice that needs to be addressed. And there are certain, um, safety methods that still need to be addressed with the risk being COVID. And so those are some things that we've seen, um, employers not recognize as a current condition or, or made the connection that, that, that COVID is a risk enough that we have to have those, those other protocols in place. Um, so, you know, PPE and hazard assessments and all those conditions are methods to determine the amount of risk and then how do we manage it? And I think there's a disjuncture there that employers don't recognize that COVID is an OSHA issue that they have to manage effectively as well. Okay.

Speaker 2: 9:14

Because I know some, you know, obviously was people were moving back into the workplace. Um, most companies had to have a plan in place. Right. You know how to, so we're going to go in place what they were going to do, not have to have the cafeteria open or whatever those are, those things that fall under OSHA,

Speaker 3: 9:34

Believe it or not. Yes. So there's two things that you've spoken about. There is actually, um, a response plan or a control plan that OSHA asks that employers have and put together, um, that all these separate conditions that they've managed, uh, travel policy, um, working at home, um, absentee policy, all those kinds of things should be put together in a single freestanding OSHA policy for COVID. All right. So it's a preparedness plan essentially, but then you also noted, um, the return to work concepts. And, um, OSHA's recently, um, listed, um, um, a large publication, I think, um, uh, I think it's OSHA publication, 39 90, uh, but that's one, that's a return to work. So she actually has a multi page document that itemizes the issues that they think should be present when there's the return to work protocols. And so many of them employers are probably already doing, um, uh, sanitizing and disinfecting and giving those controls to the employer to clean their workspace. But there's other things about, um, uh, absenteeism and how do we manage those policies when someone at home is ill, right? So there is a publication that people can go and look at that OSHA has put out that is, that respects the return to work phase that w that we're in. And if you'll take a look at those specific things, there's somewhat of a checklist. So ensure that that checklist is completed, or you have those pieces in your policy. Um, and then you're, you're going to have a much tighter return to work policy, addressing all aspects, instead of just perhaps the linear aspects that we would expect sanitizing disinfecting and those types of things. There's telecommuting policies and absentee policies and whistleblower policies that are all spoken about in that publication that, that are, that are very good to understand.

Speaker 2: 11:34

Okay. All right. Now, um, with that, as far as the OSHA, is this, I mean, help me understand when OSHA is applicable as it, is it to a particular size of business, public, private,

Speaker 3: 11:52

No. Uh, and that is, uh, often an issue that employers don't understand correctly enough. Um, so it's, if you have an employee that's working, um, then the individual is covered by the OSHA laws and regulations and it's, uh, there's public, there's private. There's, it's just, it's, it's the gamut that way. So there's no, um, there are one, one requirement is if you have 11 or more people at your facility, then you have to do the OSHA 300. So anything less than that, you don't have to do the OSHA 300. Um, but there, beyond that, there's not an indication of a head count that makes OSHA regulations apply and OSHA regulations not apply. So if you're working and you're in the environment of the SIC code and standard industrial classification code that OSHA says they cover, then the standards apply if your operation is completing that. Um, right. So if you don't use beryllium, uh, then the Berlin standard wouldn't apply, right? But the basic standards are gonna apply to most employers, uh, personal protective equipment, um, fire extinguishers, emergency evacuation, um, safety committee is not a standard, but it is a method to get you to execute what OSHA asks you to complete under their standards. So there's no numerical headcount that would apply to OSHA compliance or when the OSHA standards would not apply. Have

Speaker 2: 13:28

You had any, um, is OSHA doing any kind of response in relation to, you know, so many, um, team members have switched to working from home? Is there anything that the employer has to be concerned about or, you know, something that needs to cover that umbrella?

Speaker 3: 13:46

Oh, well, it's interesting. Yeah, it's interesting. Just because they're at home, they're working. Right. And so the condition of working is really what OSHA overseas. So we have had, uh, in our claim navigation team, we have had injuries where an employee has tripped on the kitchen table leg, which is their desk, right. And have fallen and hit the floor and had an injury. So those conditions still apply. They're not as rigorous as being on a manufacturing floor, but they still apply, especially if you're doing work on behalf of the employer, which is work. Right. So those are conditions, a little lighter, um, with respect to, um, you probably don't have, again, exposure to beryllium at home. Right. But you may have exposure to ergonomics at home, which is the office or the workplace. So the standard switch a little bit, but they're still applicable. Um, and you know, with the change in the COVID conditions, um, those still the COVID applications and the conditions of COVID risk, um, still apply at home. Um, and so those are unique things that don't differ depending on your workplace. Some things will differ PPE. You're probably not going to wear it in your kitchen when you're doing your office work. Right. But you may have ergonomics or you may have, um, uh, potential for back injury, uh, depending on what your file box is. It just really depends, but, uh, there's no exclusion for working at home. Okay.

Speaker 2: 15:13

Okay. Now, um, you know, we've brought up, you know, COVID-19 has kind of thrown a wrench in this whole thing, so many levels, but, um, how, what are you seeing in relation to if you have single location versus multiple location, uh, manufacturers and, and maybe share what's going on in that?

Speaker 3: 15:35

So there are some variables, right? If they have multiple location entities, all in one state, it makes it a little bit easier because there were state specific rules on traveling or state specific rules on quarantining that made it difficult. So oftentimes you'll see a multi location employer, um, create the policy that is the most restrictive for all their locations and that most restrictive, uh, uh, policy applies to everybody, right. Management enforcement's much easier. There's much less subjective. Um, why do they get to do this? And we don't type of thing. So with the multi-employer location with most policies, um, it's a global application, um, of the expectation. Um, so that becomes a challenge when you have multiple locations at different states. Um, but if they're all in the same state, it's just the common coordination of risk management. How do we ensure that each location is executing the policy as delivered? And there's not so many sites, specific, subjective conditions that you change. Right. And it, depending on the employer, they're going to give you that right. To make it site-specific. Um, but not. So site-specific that the application, uh, the intent of the application is different. So, um, multi-employer locations just have a stronger challenge because they have more people, more locations. I mean, that's just inherent with any type of OSHA condition. Um, but the, the COVID conditions, again, have that extra twist, if there's, um, different requirements by, by state, um, some of the locations have higher incidence rates. So Illinois was a little bit different than Indiana for, for a time. So we have people living for example, in Illinois, but they work in Indiana. So there are some complexities that way, but, um, employers just really need to think it through. And, um, my suggestion has always been, um, established one single policy and make it applicable for all locations all over for all states that makes implementation much easier and policy and procedures much easier as well. Okay. There's a lot to it. Yeah. Yes. That is, there is a lot to it.

Speaker 2: 17:53

Now, talk to me about, um, you know, you've had some worst case scenarios be a little bit about that. Um, and things that came up that either, you know, just new experiences or challenges that, um, you know, uh, manufacturers had

Speaker 3: 18:13

To deal with. So we had a few clients that, um, early on had conditions that we didn't anticipate we were going to have to manage. Right. So, um, one of them was a fatality, a COVID related fatality, which was at that time, which was considering now would be considered mid pad, mid pandemic, right. So we didn't necessarily know how to respond. Um, the agency wasn't sure how they were going to respond. Um, we, as a consulting team, we're alert, we're looking for interpretations or enforcement memos. And at that time there weren't many out in the enforcement men memos are often things that OSHA puts together that says, this is what we said, but this is how I want you interpreter. This is how I want you to execute it. Right. So I want you to have a pandemic policy, maybe the expectation, but the interpretation would be the pandemic policy should include these items. So it's short of an OSHA standard, but it gives guidance to employers on how OSHA is going to enforce, um, the activities that they've said that they're going to look for. And so at that point, we did have some difficulty because we didn't have any enforcement memos. So we felt like we were running blind really. Um, but to have a fatality that was COVID related at a facility was very difficult because we also had some other things to prove we had to prove, uh, where from contact tracing, where the fatality occurred, was it an exposure from the work site, or was it an exposure and a vocational exposure, not work site related, um, and to make sure that we made those two conditions, black and white and that they weren't gray because if it was black and white and the individual past, because of contact from a family or something outside of the work, um, uh, when OSHA on this condition, she actually came in and had a, um, a compliance inspection. And so that was very key and identifying that, yes, it was COVID related, but the contact was not at the workplace. And so what was key about that is we kind of pulled back the layers of the onion and the individual was the first individual to have a recorded COVID case at this location. So that was pretty key because if it was the first person to have a COVID case, he couldn't have gotten it at the workplace. So those became very key indicators on how we then managed going forward, um, uh, how we were going to manage, not just the additional conditions, but the perception of risk that the employees had, but also how we would respond to OSHA in the wording that we recused and the, um, mannerisms that we would use in the compliance letter. Uh, that was very key, right? So, um, those are two things that contact Tracy becomes very, very important to be able to trace the conditions of risks and to help the employees understand that the perception of risk is there, but the th the death or the passing didn't occur because of a loss at the, you know, the contact at the work site. So those were very key pieces, um, in evaluating a fatality, it was scary, but once you pulled the emotion away from it, you really had to look at the science behind it. And what records were did we have in place and to contact tracing, and how could we prove what was truth and not the perception of truth. So that was important.

Speaker 2: 21:48

And, um, I know that you had mentioned to me by happenstance, a previous client had had pandemic preparedness training before this actually hit. Um, what types of things did that training cover that helped them,

Speaker 3: 22:06

You know, anticipate what was coming? Yeah. What was coming? Yes. So, um, we did pandemic, uh, training through our online delivery system in June of 19 for this particular client. And, um, the client had, uh, matured, um, from their safety program. We've been working with them for 10 or 12 years in the city had really matured, um, all the OSHA compliant things we had completed. So the next expectation was you look beyond OSHA compliance and you go to best practice or industry practice. Um, and that was an indication, uh, we just felt some rumblings, uh, on the OSHA side of communicable disease, tuberculosis, those kinds of things, which, um, is not tackled in the bloodborne pathogen standard or any other standard that OSHA currently has. So that was, um, avoid that we felt was present. Um, the timing in part was luck, but once you have a mature program, you look to things that are risks that OSHA doesn't manage. And this happened to be one of them, what was really communicable disease was the concept. Um, and we decided to deliver it from a pandemic, um, uh, angle, um, which is the communical bowl, public disease component. Um, and so they did the training. And so with that training, it triggered certain things. They, um, I response plan, how did we manage it now? I'll be honest with you. Response planning for that company has changed three or four times because our response over time has changed, right? So it's not just been, uh, I'm going to create a plan and put it in a binder and put it on the shelf. But this was a living document that three or four times we changed it, we've added policies when the risk became greater, or they had clients that said, uh, we've had a, um, a condition that I want you guys to respond to, and we put it in policy, right. So we would talk about it in the toolbox talk, and then we would memorialize it into a policy. Um, but it, it helped us, or allowed us to anticipate those conditions that I don't think many employers would have tackled. Had they not been working outside of OSHA compliance into an industry best practice, or just a broad management of risk. Right. So, um, so yeah, that was, um, that felt good. So it got them started in advance, you know, leading the race. And then, uh, we've, we've been really successful, no direct contact conditions and no fatalities relative to COVID. And so it just, it gets you out of the gate a lot quicker. So it was a good opportunity sure. Better than

Speaker 2: 24:47

At least some direction, instead of, you know, right.

Speaker 3: 24:50

So you had some right. And then it has to mature. I mean, that's really the, the, what both, what policies do when you're doing risk management, you start with the core concept. And as you roll that out, you're going to get site specific expectations. And then you manage those site specific expectations. Each client is going to have their unique application and you need processes and things that you could start with something that's OSHA related, but then you have to make it site specific. So that's really what we did. We started with that core pandemic, public communicable disease policy. And then we rolled out this, this company happened to be a contractor, which is unique in that they don't have their employees at the same facility, seven days a week or five days a week. Right. They would roll their employees out to do service work at different locations. So that was a different twist that we had to evaluate. So there were conditions, um, uh, but having that pandemic training early on, got us out of the gate and we weren't reacting all the time. We were had a proactive approach to what we were going to do. And so it was a little bit less stressful for the employees because they could anticipate what our thought process was in that, in that policy and how we were going to respond well from the employee

Speaker 2: 26:05

Standpoint, just knowing that there was something proactive already in place, right. Management had already been thinking about this and, you know, what do we do, uh, that half that would have to be a little bit comforting because as an employee, the first thing you worry about is, oh my gosh, what if I get this and take it home to my family and my kids and you know,

Speaker 3: 26:25

All that. Right. Yeah. So I think just getting out of the box early gave us peace of mind on how to manage it proactively and not reactively. Although reactive sometimes is the way you have to manage an event or an accident or a loss of risk. Um, but it is comforting to feel like we don't have to do it, um, quickly, which sometimes leads to stops and starts or interpretations that management may not know what they're talking about, you know, and that's, those are not, um, conditions that you want to, um, convey to your employees. Uh, they need to feel safe and safety is part of having things done proactively.

Speaker 2: 27:08

Sure, sure. Um, now we talked a little bit about, um, as far as, you know, with the fatalities and, you know, whether it starts, you know, trying to, through tracking, figuring out where it started, if it's at work or not at work and what have you. Um, but why don't you talk to me about what are some of the most important things clients, manufacturers need to know? Um, because we don't always know what we don't know. Right. And once we know it, where do we go for help? How do we execute? Right. So to your attorney, do you go to HR for, you know, policies or, you know, that kind of thing.

Speaker 3: 27:53

Right. So what we see, um, what we've seen recently is employers having difficulty, um, executing. So we all do very well at developing a policy, right? And the policy is developed with a key group of people, whether it be the management team or the safety committee team. But oftentimes we have, um, struggles getting that policy to ha to be boots on the ground, right. To train the employees, to have the employees understand the reason for the policy. Um, and just to complete that circle of the policy, you don't create a policy, put it in your binder and sit it on your shelf and let it gather dust, right? A policy should really be something that people reflect on to make the decisions based on what the policy is saying. So those are conditions that we find employers struggle with. Um, creating a policy is not the difficult part, it's the execution and the training, and that like a pyramid, you start with the policy of the tab, which takes a smaller amount of time, but you get dark down towards the wide part of the pyramid and it takes more time. So the base of the pyramid is the amount of time it takes to get people trained and to get people on board and to give them empowerment, to understand the benefits of the policy. And so those are pretty common struggles that we see from a risk management side. Um, if they don't clearly know what to do, they also sometimes don't know where to find the resources, right. So the common resources have been directed is, um, uh, your insurance broker or your insurance agent, um, and an attorney. Um, but sometimes those are probably not the best sources just because that's not their area of expertise. Um, we often like to say, we'd like to be one of the top three business cards in, uh, management teams, you know, card file, right. Because we can satisfy those conditions, perhaps that manufacturers didn't realize that there was a niche professional that could provide that information. I mean, you don't go out looking for an OSHA consultant, right? Oftentimes you look for them once you have the issues, but the conditions that we really like to have employers do is manage it as effectively as you manage quality, um, or you manage, um, hiring, right. They should be one of your top three and safety and environmental compliance is something that, um, not only provides worth but value, but employee retention, um, comfort and less stress. And, um, just nice to pull somebody up on your contact list on your phone and say, Hey, OSHA's here. Um, as opposed to trying to look in the yellow book pages, right. And trying to figure out who should I call. So that's the relationship that we try and manage. And, uh, um, it just gives peace of mind to people, uh, and companies, you know, in the midst of, of a risk.

Speaker 2: 30:51

Right, right. And I'm sure obviously proactive is much better than reactive.

Speaker 3: 30:56

Absolutely. I mean, we, we always say it is right, but it's, it's really putting the, the, the metal to the, to the rubber, the rubber to the road type of thing. Um, uh, often oftentimes it's on an, a manufacturers with wishlist, but they don't know where to go to start executing that wishlist. So that's part of the service that we try and help. I mean, when I was in ocean specter, um, we often found it beneficial that as long as we were there, the employer now had some knowledge on how to complete what they were supposed to complete. But if you're an employer and you don't know what you don't know, how do you execute? Right. So many times that we, there was that service portion of our OSHA visit is that, um, here's the website, which is osha.gov, which is a good place just to get started very complex website, but it's got all the current standards and letters of interpretation and all those kinds of things that you would need to at least get you started. So that would be a good place just to open that webpage up and give it a shot. And then you'll start understanding the concepts and actually have a resource to go to, to help you complete those requirements.

Speaker 2: 32:11

Okay, great, great, uh, great advice, uh, as far as just, you know, because that's the first thing that comes to my mind is, wow, what do I do exactly. Wouldn't be caught with yeah. Pants down. So to be able to figure out what I, where I should go.

Speaker 3: 32:29

Right.

Speaker 2: 32:31

Well, is there anything else that you'd like to add for today's meeting that we've talked about? Any other

Speaker 3: 32:36

Words of, I think the only I'll add is it's only timely to COVID. There has been some, uh, interim enforcement guidelines that OSHA has put on the osha.gov, or if you're in Indiana on the website, um, and it gives, uh, employers the flavor of what to expect when OSHA comes for a visit, if they're actually going to physically come on site, um, uh, or if they're not going to come on site, what states they may not address onsite. So if you have a high, um, COVID, um, population or a high COVID, um, incident rate, then OSHA is going to handle those OSHA inspections for COVID specifically, either via mail or email or phone calls. So they won't necessarily come on site unless, you know, the fatality, they didn't even come on site that we were involved with. So I would just encourage people to keep abreast of the OSHA, interim enforcement guidelines. And again, there's two of them, there are on low show website. Now that'll give you a comfort level for how OSHA is addressing those concerns, um, and how to prepare your facility for things that they will be looking for. So I guess in the short term, that would be something to help employers under the current COVID crisis. Okay. And that's

Speaker 2: 33:58

A really good point because I've spoken to a variety of professionals, uh, related to COVID from different angles. And everybody always mentions the CDC. You know, you're the first that says, Hey, he really needs to look at OSHA. And this is where you go to get you started. That's not something that maybe, you know, is automatically known or, you know,

Speaker 3: 34:22

Yeah. It's, um, I would have liked to have seen, um, OSHA to be a little bit more, um, publicly vocal in the expectations. Um, but if you dig down on the OSHA website, there is, um, expectations. So if you do your hazard assessment, which is the protocol for determining risk, and once you find COVID being a risk, then you have to figure out next process is how do I manage it? And so that management does come along with understanding enforcement guidelines and the flavor of what OSHA's looking for, which right now is mostly training. So how have I indicated to my employees that this is a condition that they have to manage and what our policies are here at the facility? So, um, when I looked at the website, um, a couple of days ago, that is what they were emphasizing on. The return to work brochure is the training component can be done in toolbox talks. It can be done in zoom calls. It could be done in a mass email distribution, but may make it regular and make it, um, something that people can anticipate and use as a resource. So the training component is becoming very important or more important now under the COVID conditions, um, on what the policies are and how to react to it that, um, if employers have no other time than going to the CDC or going to a website that already has pre-established toolbox talks relative to COVID, that's a really good start. Um, we don't always have a lot of time to develop our own, but there are some out there that they can use, um, which will, uh, document and prove that the training concept is being completed. Okay.

Speaker 2: 36:00

Okay. Well, thanks for that great information. Uh, it's a pleasure to have you on the show today. Um, also thanks to our audience for tuning in to buck root TV today. We hope you've enjoyed the show. Um, if you have any questions or thoughts, please be sure to let us know. And don't forget if you enjoyed the show today, please be sure to subscribe to our channel buck room TV

Speaker 1: 36:22

Again, Christy. Thanks so much. My pleasure. Thank you. Thank you for listening to the Buckaroo marketing new media podcast. If you'd like to learn more about B2B marketing for manufacturing and related industries, please visit us like go book a route.com.