That philosophy, which was a recurring theme at ASSE's annual conference in New Orleans, is the foundation of Corning Inc.'s risk-based safety and health auditing process, according to Larry DeWitt, CSP, manager of safety processes for Corning Worldwide Safety Management Services.
DeWitt, who admits he used to believe the best way to correct safety issues at Corning facilities was to "audit the dickens out of them," told attendees at a June 13 ASSE session that he's come to the conclusion that incessant auditing of problem facilities isn't the answer.
"The answer is to work with them," DeWitt said. "Partner with them until they get better. Use audit processes as a positive reinforcement" to give facilities a mechanism to show how much progress they've made on safety initiatives.
Corning, a diversified technology company based in Corning, N.Y., introduced its risk-based auditing system Jan. 1, 2004. The heart of the system is a formula that determines how often Corning facilities are audited either every 2, 3 or 4 years based on several factors, including each facility's hazard potential.
So far, feedback from Corning facilities has been positive "they see us [working] in a collaborative mode, not an auditing or adversarial mode" and it has opened up more time for Corning's corporate EHS staff to focus on the most important safety and health priorities during their audits, DeWitt noted.
Instead of visiting a facility and spending the whole time on the audit, DeWitt explained that corporate safety professionals now spend the first day or two reviewing past audit results and recommendations for the facility and the next "3 or 4 out of seven [days] helping them." That means, among other things, "showing them what safety is all about and what the role of the safety manager is at that facility."
The focus now, he added, is, "How can we help you?"
Why the Change?
Corning, which employees 25,000 people in 70-plus facilities in 19 countries, previously audited most of its facilities every year or two, according to DeWitt. Some of those facilities are getting outright "humongous," which made audits time-consuming. "Our R & D facility took me 7 days," DeWitt explained.
Because of the enormity of the challenge to audit so many facilities Corning's corporate EHS staff is on the road 60 percent of the time, according to DeWitt top safety professionals took a long, hard look at "how we're managing our resources." They also took into consideration feedback they were getting from plant managers, who lamented that they weren't getting enough time to implement safety recommendations made during audits.
"[They told us], 'why don't you take time to help and be actively engaged in our processes rather than come back in a year or two to do another audit?'" DeWitt said.
That kind of feedback prompted DeWitt to suggest, "'Let's change our thinking.'"
DeWitt and other top safety professionals at Corning devised a formula to quantitatively determine how often Corning's plants should be audited. The audit frequency formula takes into consideration three risk factors: business classification, facility population and hazard factors.
- Business classification This factor assigns a number between 1 and 4 to facilities based on the nature and complexity of their operations. It takes into consideration whether a facility has multiple-step operations, complex lab operations, hazardous processes, physical hazards or chemical/biological hazards. An office building would be a 1 (lowest complexity), while a large-scale manufacturing facility would be a 4 (highest complexity).
- Facility population A scale from 1 to 3 ranks the exposure population, with 1 being a facility having fewer than 100 people; 2 being a facility with between 100 and 500 people; and 3 being a facility with a population of more than 500 people. DeWitt noted that the exposure population for a chemical manufacturing facility might include residents living within a certain radius of the plant, as they could be affected by an incident involving a chemical release.
- Hazard factors A scale from 1 to 3 ranks facilities based on the number of "specifically pre-identified" process, physical, chemical and biological hazard factors. A rating of 1 is assigned to facilities with zero to one hazard factor, a rating of 2 is assigned to facilities with two to seven hazard factors and a rating of 3 is assigned to facilities with greater than eight hazard factors. Examples of process hazard factors include melting units, furnaces, kilns, injection molding, plating, molten processes and cable manufacturing. Physical hazard factors include ionizing radiation, noise, temperature extremes and ergonomics. DeWitt explained that there's "no attempt to quantify" how many individual hazards are present in a facility; instead, if a facility has one of the hazard factors such as ergonomic hazards "that's probably going to count as one" factor.
As for the numbers Corning chose for its scale rankings, DeWitt said it was a fairly arbitrary decision.
"For business classification, we decided on a scale of 1 to 4. But it doesn't matter what numbers you use. Just start with something," DeWitt explained. "There's no magic number to 4 for Corning it just seemed to fit."
Determining Audit Frequency
The hazard rating category (HRC) is a number that determines if a facility will be audited on a 2-, 3- or 4-year cycle.
To determine a facility's HRC, the risk ratings for business classification (BC), facility population (FP) and hazard factors (HF) all detailed above are multiplied. The result is a number Corning refers to as the maximum potential loss (MPL). The MPL scale ranges from 1 to 36.
The formula looks like this:
(BC) x (FP) x (HF) = MPL
A facility's MPL is used to determine its HRC, which is the determinant of how often it gets audited. So the entire formula is:
(HRC) = MPL = (BC x FP x HF)
There are three HRC categories: A, B or C. HRC-A facilities have an MPL of 1 to 8 and are audited the least frequently; HRC-C facilities have an MPL of 17 to 36 and are audited the most frequently.
- HRC-A (MPL: 1-8) facilities are audited every 4 years and are characterized as having the "potential for incidents resulting in physical injury, property damage or business disruption." Lower risk.
- HRC-B (MPL: 9-16) facilities are audited every 3 years and are characterized as having the "potential for major incidents." Moderate risk.
- HRC-C (MPL: 17-36) facilities are audited every 2 years and have the "potential for high-profile incidents resulting in fatalities … legal action or significant business loss." Higher risk.
There are situations in which corporate safety personnel might "override" a facility's HRC rating and its corresponding audit schedule such as when a plant manager requests more frequent audits or when a plant's compliance history and injury/illness trends warrant more scrutiny. Sometimes, a plant's safety record is "so horrendous that you need that added focus," DeWitt noted.
"If someone's on a 3- or 4-year cycle, you might want to put them on a 2-year scale for a while," DeWitt said.
Still, DeWitt added that there shouldn't be much variation from the HRC audit frequency system.
Because warehouses and offices generally are less hazardous than other operations, DeWitt noted that those facilities, while still inspected by safety professionals, are not subject to Corning's risk-based audit frequency schedule.