There are countless numbers of companies, both small and large, that are assigning EHS responsibilities as a collateral duty. We most frequently find this in general industry, particularly the warehousing, production and manufacturing environments. At first glance, this appears to be based on a sound business concept of more productivity with less overhead, or getting "more bang for the buck."
However, these companies are entrusting their safety management system to individuals with little-to-no training or experience in a field that continually is evolving. More often than not, we find the safety management system (SMS) in these companies is nothing more than a few informal policies or, more often, just meeting OSHA reporting requirements assigned to the human resources professional who handles workers' compensation claims.
It is within these organizations that we can find no discernible safety management system. We may see informal lockout/tagout and HazCom programs, but certainly no written policies or programs. There are no functional safety committees, no workplace hazard analysis, no forklift training or routine facility audits. It is within these organizations too that we find a lack of machine guarding, missing, damaged or unmaintained PPE, electrical issues, etc. Often, these are the businesses that assign responsibility for safety to laymen as a collateral duty.
Safety as a collateral job assignment does not work, and here's why.
Safety Is Not the Primary Focus
The HR professional will spend the bulk of his or her time on HR issues. Maintenance managers primarily will focus on equipment and/or building maintenance and repairs while the plant manager is basing his/her decisions on schedules and customer commitments. Safety, in these environments, is an afterthought, not a value or even a priority.
While there may be folks who earnestly attempt to fill the role in safety and take on the responsibility of a safety coordinator, safety liaison or safety officer, many feel as though they have been saddled with it, and most do not have the background necessary to effectively handle these responsibilities. These individuals often find themselves in a position that seems overwhelming. For example:
As the Dec. 1, 2013 GHS deadline approached, an HR manager who had been assigned the additional role of safety coordinator for her company found herself in the position of having to train her entire facility on the GHS label and safety data sheet changes to the HazCom standard. The manager found out about this requirement during the second week of November.
Her state offered a course on the changes and how to present the changes to the workforce. It was during this course that the manager was advised that her plan to send out a notice of the changes in employees' paychecks was not acceptable training, nor could she request an extension of the deadline from OSHA. She also came to realize, while taking the course, that her manufacturing company did not have a HazCom program in place, even though they dealt with some hazardous chemicals (albeit in extremely limited quantities). In fact, her company did not have a single MSDS or SDS on site. Until she took the course, she did not understand what OSHA required.
In another case, a maintenance/safety manager was terminated by his employer for poor job performance following an OSHA site visit that occurred in response to a complaint. While there was an informal lockout/tagout program in effect, personal protective equipment was available and safety data sheets were available, there were no formal programs in place, training was not being conducted, PIV operators had not been certified and there were serious electrical safety violations throughout the facility.
Citations were issued, and after penalty reductions, the company still had to pay a few thousand dollars in fines. The manager later stated he thought he was in compliance but had a difficult time interpreting the standards.
These two cases have quite a bit in common. Although one company was relatively small – employing 50 employees – the other was a mid-size company with more than 300 workers on the roster. Both companies had more than one manager assigned to duties outside of his/her area of expertise as a cost-saving measure.
Neither of the managers in the cases discussed, had any formal EHS training, neither had any experience in the safety field and both thought they had an understanding of what the job entailed.
Neither company was willing to invest the time or money in training the managers in the most basic aspects of EHS (an OSHA 10-hour course, for example), yet both companies expected the managers to be able to effectively administer safety in their facilities.
Both companies had an opportunity to learn valuable lessons from their respective cases, however, the company in the second case took punitive action against one individual, rather than proactive measures to establish an safety management system within the company.
Considering the economic hardships that began in late 2007 and the struggles faced by industry to recover, it is understandable that action had to be taken to reduce costs and streamline businesses. Safety is a budgetary line item that all too often is cut or eliminated entirely. While the economy continues to improve, we find that safety is one of the items that is not making it back into the budget with any haste, if at all. Companies that have made it this far by doubling up on the responsibilities of employees while salaries remain status quo are not too likely to change.
Having interviewed scores of individuals who have been assigned safety obligations in addition to their "regular" duties, it was determined that nearly all were directed to devote 25 percent to 30 percent of their time to EHS concerns and the remainder to their primary job title responsibilities. Nearly all of them found it impossible to allot that amount of time to safety and perform their primary responsibilities to a satisfactory level. All of them reported that they are given no additional resources in the form of time, budget or assistance to effectively manage EHS. Most telling of all, 100 percent of them said their annual job performance evaluation focuses entirely on their primary job description.
One human resources manager reported that the time consumed by payroll, benefits administration, the interview and hiring process, terminations and unemployment hearings leaves him approximately three hours per month, on average, to attend to safety issues. "I just can't make it a priority," he said.
Plant managers and production managers similarly are distracted. While they seem to spend the most time at their facilities (an average of 56 hours per week), they spend the least amount of time on safety concerns. One manufacturing plant production manager said, "Let's be real: At the end of the day, it's all about the numbers."
Most of the maintenance managers interviewed agreed that their primary focus is on equipment maintenance and repair, parts inventory, dealing with outside contractors and scheduling. Time spent on EHS issues primarily is devoted to the issues with which they are the most familiar and comfortable, which included lockout/tagout, PPE and HazCom. When asked about the GHS changes to the HazCom standard – particularly the training requirements – a maintenance manager asked me, "How are you supposed to find out about stuff like this?"
The same sentiment holds true for nearly everyone interviewed, including administrative assistants, foremen and a marketing manager who all were assigned EHS responsibilities in conjunction with their normal job duties. Outside of some of the HR professionals, none of the people interviewed for this article had any knowledge of OSHA 300 or 300A logs/forms, yet these are the folks to whom company leaders are entrusting their company's safety management systems.
In these cases, the primary building blocks to any safety management system – those being information and education – are missing. People are thrust into a position to administer safety programs, and do not know where to begin. They do not know where to go or who to ask for the basic information necessary to be successful. They do not know where to find federal, state or local standards, laws or ordinances, nor do they have the education or experience necessary to interpret them once they find them.
Because of this, documentation is lacking and in many cases, incomplete and inaccurate and in extreme cases, fabricated. Training – if it occurs at all – does not meet the requirements of the standards. Records are not maintained properly or are not maintained for the correct period of time.
Occupational health and safety is a living, breathing organism that constantly is evolving out of necessity. The evolution does not stop because the economy takes a downturn or because a company has a bad year. People responsible for the safety and health of employees have an obligation to stay current and continue their education in the field. Handling safety as an addendum to one's primary job assignment is not conducive to the process.
This is not a new problem; it has been identified by safety professionals for years. If we can agree that safety as collateral duty is not in the best interest of anyone, then we agree that there needs to be a solution. As with all things safety, the solution, if it cannot be regulated, requires management buy-in.
But who makes the pitch to management? Certainly not the individual assigned the extra responsibility; admitting that you need help, are not qualified or are overwhelmed could, in some instances, be a career-ending move.
It is our responsibility as safety professionals to spread the word that safety cannot be a part-time job, performed by people who have other, more pressing responsibilities. We can do this through consultations, networking events, speaking engagements and conversations.
That is not to say OSHA is completely in the clear. OSHA shares some of the responsibility, and needs better marketing of their "product." But, as safety professionals, we all share in the responsibility of getting the word out. We need to lobby for safety management systems as individuals or via our professional organizations.
Consider it a collateral duty.
Rick Taft is the environmental health and safety manager for Pitney Bowes Presort Services. He is a member of the American Society of Safety Engineers and is a qualified safety committee instructor for the state of Pennsylvania. Taft is considered a subject matter expert on the control of hazardous energy standard (29 CFR 1910.147) and consults and speaks on the topic. He can be reached at [email protected]