Developing an Investigative Photography Program

If safety professionals and managers are going to use photography in safety and health program management or for investigative purposes then thoughtful consideration must be given to developing the appropriate policy and response capability. You must implement the elements of an investigative photography program, by evaluating your needs for camera equipment, film, photograph storage, and personnel training.

Occupational Safety and Health Administration regulations require employers to implement a number of programs in support of effective safety management. Photographs can be a valuable resource for the safety and health professional. A good, well thought out photography program can provide support for standard operating procedures and prevention strategies, hazard control or abatement, documenting accident experiences, and training. With current technology, photography can be easily used in desktop publishing to create a variety of advantages in communicating important information through a media, which is very learner friendly.

Why do safety professionals need a program for investigative photography? Let us answer that question by thinking about a potential scenario. An accident has occurred which you believe may result in some form of litigation. You decide to take pictures and brief your management with those pictures. Not a bad idea. After some time, a complaint is filed with OSHA, and during the investigation it is learned that you have photos. Of course they want to see them. The photos support OSHA's position that an alleged violation may have existed. The photographs you took are now evidence, which is going to be used to support the violation.

If you take photos you should offer them to the authorities and other investigators; that is really the principle behind having a good program and an effective response with photo documentation. But remember you did not have a program. You really cannot say that your response was part of a planned contingency. You really cannot testify to a chain of custody because you have no policy for one. You did not write down the number of photos you took. You did not show a reference in any photos so the shadows and poor lighting distort the image. They do not support relative conclusions or they may give the appearance the condition is worse than it actually is.

Keep in mind that as the quality and purpose of your photos are scrutinized you will have to keep the best face on a argument that you did not think that taking pictures required a lot of training and that is why you did not get any. Poor photography, or none, can result in serious legal consequences. A single lawsuit avoided or won by good photography will pay for your program costs many times over.

I once saw a safety professional lecturing from a slide showing the abatement of a hazardous condition. Someone in the room asked the speaker about the two apparent hazardous conditions in the photo background. The speaker was visibly nervous by the inquiry.

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