
The Occupational Safety and Health Review Commission (OSHRC) recently upheld a citation after a worker was fatally struck by a backing truck. The employer had written policies on safe backing and struck-by hazards, but the Commission found they were not communicated, enforced, or integrated into daily operations.
The lesson is clear: written policies alone do not protect workers. Implementation does. Training, supervision, and site-specific controls must be active and effective. OSHA made it clear that a plan sitting on a shelf does not meet an employer’s obligations under the General Duty Clause.
Why It Matters for Dealers
Although this case involved another industry, the warning applies directly to dealerships and service operations:
- Paper is not protection: OSHA inspectors will look past binders, manuals, and posters. What matters is whether employees and supervisors actually follow safety procedures in real time.
- Training has to stick: A quick video or orientation is not enough. Employees need to understand how the rules apply in their workspace, show they can perform them correctly, and know what happens if they do not.
- Supervision and enforcement: Policies without oversight are invisible. Managers and service directors must audit, enforce, and document corrective action when rules are ignored.
- Defensibility after an incident: After an accident, the question is not just “did you have a policy?” but “can you prove you trained, enforced, and corrected?” That is what separates a defensible program from a citation.
Bottom Line
This decision reinforces that compliance is not about paper; it is about practice. Dealers should ask: Are our safety programs actually shaping daily operations, or are they sitting in a manual? The answer could determine not only OSHA liability, but whether employees go home safe at the end of the day.
How ComplyAuto Safety Helps
At ComplyAuto, we know OSHA compliance takes more than templates. Our Safety platform helps dealers move from paper to practice by:
- Delivering customized walkthroughs and inspections for every dealership work area.
- Building practical checklists and controls that fit service bays, parts departments, and lots.
- Training employees with tools that measure comprehension, not just attendance.
- Documenting enforcement and corrective actions so programs are defensible when OSHA comes knocking.
A written plan is only the starting point. ComplyAuto Safety gives dealerships the systems, documentation, and culture to make safety real and to keep employees safe.