World-Class Safety: Best Practices Versus Regulatory Compliance

Deborah Roy, MPH, RN, COHN-S, CET, CSP, offered a brief history of regulatory action in the United States to attendees at the Achieving World-Class Safety Seminar in New Orleans this week to prove that compliance is not enough to create a world-class safety program.

She talked about factory inspectors in Massachusetts in 1867, Congress passing workers' compensation legislation in 1908, the Triangle Factory fire in 1911, and the creation of OSHA in 1970. Unfortunately, she noted, regulations are not enough: fatalities, injuries and illnesses continue to occur in workplaces across the United States.

"One hundred percent compliance with OSHA standards was never intended to be the ultimate safety system," said Roy. "Regulations are a minimum standard, yet many U.S. companies are striving for those minimum standards, not identifying the risks and eliminating the opportunity for injuries and illnesses."

OSHA standards aren't enough, she added, because "much of OSHA enforcement is spent on compliance with specific standards even if a lack of compliance has not resulted in injury."

As an example of her point, she mentioned the lockout/tagout standard, which is a frequently cited OSHA violation, even at companies where no major injuries related to lockout/tagout have occurred. Roy noted that:

  • .3 percent of all accidents result in a major injury
  • 8.8 percent of all accidents result in a minor injury
  • 90.9 percent of all accidents result in no injuries

She said companies are being forced to look outside the box when it comes to compliance because of foreign-based parent corporations, worker's compensation costs, corporate guidelines, competition with other vendors, benchmarking and stagnating injury statistics.

"In Europe, the EU relies on companies to make decisions based on an evaluation of risk," Roy noted. Performance-based standards are included to address specifics such as the need for personal protective equipment and safety machines, but European standards do not include the specifics found in OSHA regulations, according to her.

"Safety needs to be one of the core values in an organization in order to have a successful safety program," said Roy. "Unfortunately, most organizations do not make the necessary organizational changes to prevent a disaster before one actually occurs. It usually takes the ultimate failure [fatality, major injury, environmental release] for cultural safety change to occur in a meaningful way."

She suggests companies adopt a best-practices approach that includes benchmarking with other companies that have outstanding safety processes, and adopt a safety management system. "The key to a management system is the methodical and systematic control of business processes, in order to achieve pre-determined objectives," said Roy. She offers these simple steps:

  • Plan: Make plans to improve safety
  • Do: Carry out the plans
  • Check: Check the actual results; do they fulfill the aims of the plans?
  • Act: Correct where something has gone wrong and, where necessary or desirable, adjust the plans so that things go better from now on.

She offers OSHA's Voluntary Protection Program and the chemical industry's Responsible Care program as two examples of ways companies can move beyond compliance and toward best practices.

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