OSHA vs. Excellence in Safety Management

By integrating safety into its management system, any company can take these simple steps to boost its safety performance.

OSHA has had a profound influence on the safety profession, and not all of it has been good. In fact, OSHA's influence may have gotten in the way of developing good workplace systems for injury and illness prevention. The reason is that OSHA compliance doesn't do much to build organizational safety culture (the term "safety culture" refers to a workplace where it is accepted that safety is essential to daily operations). To explore that statement, let's look at how OSHA and the safety profession interact.

The safety profession has a love/hate relationship with OSHA. OSHA's regulations contain many essentials such as lockout/tagout, trench protection and fall protection. The existence of OSHA has undoubtedly meant the creation of many safety jobs, with many of us justifying much of our employment on the basis of complying with regulations. Our professional publications use a lot of their pages on OSHA topics. For example, a recent newsletter from an American Society of Safety Engineers' chapter contained three articles, all of them about various OSHA regulations and enforcement. An appearance by an OSHA official at a professional gathering is a sure-fire draw. The mention of a possible OSHA violation can even be a helpful motivational tool that the safety manager can use to influence other managers. That is the love side of our relationship, maybe almost an obsession.

What about the hate side? We can have contempt for the agency's politics, and mourn the shortcomings of the enforcement staff. We are well aware that the OSHA regulations that give us influence and job security are sorely lacking in their ability to reduce the most common, most costly injuries. The appearance of an OSHA inspector at our doors is hardly a welcome sight. Few regard OSHA as a full partner in worker safety in spite of its consultation efforts. That's too bad, because OSHA's compliance staff has many diligent, qualified people who are trying to save lives.

The influence of OSHA affects not only what gets done, but also how it gets done. Capital expenditures are an example. Having the clout of an OSHA regulation behind a request from a safety manager can get things done without having to do the usual cost justification work that any other department would have to do to request funds. This has possibly contributed to the thought that workplace safety is centered on complying with regulations for safety training, equipment, and so on. At least, this gets a lot of good things done.

On the flip side, compliance with some of the rules seems to pile up paper and not accomplish much compared to the effort. Companies working in "OSHA mode" can spend so much time and energy on compliance that little gets done outside the regulatory requirements. Most of us have heard safety-related disputes settled with something like, "We'll do what OSHA requires, and no more."

We need to get past working in OSHA mode if we are going to truly succeed in managing safety and reducing losses. For the rest of this article, there will be no more mention of OSHA or any other regulatory entity. We will discuss the basics of looking at safety as a manageable quantity, not a regulatory obligation.

Managing Safety

Successful companies have an organized approach to management that usually follows some common themes (of course with variations). Everyone in the organization is aware of a comprehensive package of critical, positive success factors such as quality, on-time delivery, efficiency, productivity and customer satisfaction. The uppermost management establishes aggressive but attainable goals for these critical factors, and pushes the importance of the goals throughout the organization.

Along with responsibility for their goals, everyone has opportunities for involvement in improvement of the processes used to achieve the goals. Any failure to achieve is analyzed and efforts made to prevent its reoccurrence.

Managers will constantly monitor their workers and provide good coaching and feedback. Rather than just being hired help, workers are allowed to feel like useful, important members of the team. Metrics are developed for the important parameters, and the status of each metric shared frequently with employees at all levels. Performance appraisals are tied into the relevant metrics. Top management stays on their message, frequently discussing the important metrics at meetings and in one-on-one contacts with workers.

After examining how companies that succeed in preventing occupational injuries and illnesses function, a similar pattern is seen. Successful companies treat occupational safety and health like all the other important operational quantities.

Why not? It just makes sense that once we have found a well-proven way to manage a business, it would work in lots of areas, including safety and health matters. Not only work, but also work better than having one culture for production parameters and a whole separate system for safety and health.

How can this idea be applied to our workplaces? Treat safety like all the other important quantities a normal part of doing business.

Good Measurements

An accident is a failure, just like a machine breakdown, a forgotten invoice, a patient given the wrong medicine or a part rejected by a customer. We can put systems in place that can help manage exposures to these failures.

We will need good comprehensive measures to monitor our individual and group activities to reduce the failures, and not just count the failures themselves. Nothing's wrong with looking at frequency and severity of injuries, injury rates, etc., but these are only failure quantities. We need to create metrics to get safety and health into the mainstream. Safety contacts, attendance at safety meetings, formal individual follow-ups to safety training, and various participation activities are among the many other creative, positive quantities that can be observed.

Observation allows us to bring safety and health up on the radar. Looking at things logically, it makes sense that if we monitor one quantity on an hourly basis, chart it, post it, discuss it daily, and are paid based on it, then that quantity would eclipse another quantity that only came up at a monthly meeting.

This is the reason that so many hourly people think that their employer cares first about production: production dominates the message. It's not that top management doesn't care about safety; it's just that they have not realized the necessity of getting as involved and visible in safety as they have in the things that are more familiar to them.

For years, OSHA has been pushing "management commitment." The irony is that in our enthusiasm to comply with its regulations, some of us have overlooked this important concept and have focused on compliance activities rather than effective performance improvement activities.

We have to think about the message. To avoid diminishing the importance of accident prevention, work on ways to make it a normal part of daily activities. Set standards, observe, count, measure against goals, chart, discuss along with other important metrics in meetings, etc. Post metrics by department, just like productivity, quality and other performance measures.

Incorporate safety goals into performance evaluations. These should measure what people do for safety rather than the outcome of injuries. Safety activities should be a large enough part to make them important, say 20 percent of the total evaluation. It is particularly important for supervisors: some companies require supervisors to do one JSA per month, attend the same safety training attended by their people, attach a root cause analysis to each accident report, or get accident reports to HR promptly.

Train Like You Mean It

Training is an important part of workplace initiatives, but if you want training to succeed, you have to train like you mean it. High impact, effective training will be geared at the eventual application of the training to the workplace, not getting documentation to prove you satisfied a regulatory requirement.

A key is to create training content that revolves around the real workplace, not generic training using a tape. Participation that draws in all attendees raises the quality. Questions and scenarios can relate to real work situations, pictures and videos show real work areas, and employees can be brought into demonstrations.

Explain the value of the training. If the training really means something, it will help everyone. A sense of importance helps keep everyone awake. Telling a group that they are in training because "OSHA says we have to do this" takes away from the sense that it is being done because it will be beneficial. Never admit you are training because you have to because of a regulation, that you want to get it over with, or say anything about taking time away from production. If we don't care about training, why should employees? Training that is worth doing will help production.

All supervisors should sit in and participate in training, not stand in back and talk. Background chatter from managers undermines the importance of training. Moreover, how will supervisors know if employees are practicing what they learned if the supervisors don't learn it as well? Certainly, these supervisors would be more attentive if the training was about an important production issue. If we push safety away from compliance and towards the mainstream of normal production metrics, we will help make safety into an important production issue in its own right.

Supervisors should always follow-up after training, watching the students practice and use their new skills, with lots of good feedback as to how they did. Retrain and observe again when employees don't seem to get it. This seems obvious outside the context of safety training. Remember how your dad taught you to drive? He probably didn't just pop in a training video and come back when it was over!

Put safety materials into sensible language. There were so many complaints about regulations that only a lawyer could read that OSHA changed their style to plain language. Now that the plain language regulations are available, the older ones are comparatively almost painful to read. How many companies now put their safety programs into plain language? There are still plenty that don't. Think about the audience. Not everyone reading your programs will be a poor reader, but nobody likes to read that cumbersome legalese.

Getting away from working in the OSHA mode and moving safety and health into the mainstream will make it a "normal" part of everyone's responsibilities. An organization that talks about safety objectives in the same terms (using the same charts), in the same places and at the same times as other production metrics, and treats safety like it is truly important, will do much to improve safety and health performance in its workplace.

About the author: William H. Kincaid, P.E., CSP is a senior loss control consultant for Lockton Insurance Cos. in St. Louis. Before becoming a consultant, he was an OSHA safety engineer specializing in ergonomics, "significant cases" and fatality inspections. He earned his B.S. in mechanical engineering from Washington University in St. Louis and is a registered professional engineer with 12 years' experience as a production manager.

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