Reducing Workplace Injuries by Building a Business Culture Written by Bill Taylor, CSP

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1 WHITE PAPER Reducing Workplace Injuries by Building a Business Culture Written by Bill Taylor, CSP Forty years ago, OSHA was in its infancy and adjusting to new workplace safety laws and OSHA compliance was moving at a snail s pace. No one wanted employees to get hurt on the job, but safety programs at the time were woefully inadequate. Most employers today recognize the importance of employee safety. They are aware they have, not only a legal obligation to protect workers, but a moral and ethical responsibility as well. With more universities offering far more educational opportunities today, there are many qualified EHS professionals entering the workforce. Therein Bill Taylor, CSP lies the problem with creating a culture of worker protection. While we are Principal Safety Scientist getting a steady flow of well-trained EHS professionals with a passion to safeguard workers, the traditional undergraduate studies in other disciplines such as business administration, economics and accounting, which often lead to senior management positions, do little to train future plant managers and CEOs in workplace safety and where safety fits into the organizational hierarchy. As a result, the senior managers often leave management of the safety system to the subject matter experts-those identified as the safety managers. Thus, many employers are still living in the '70s when it comes to managing employee safety - meaning, they are still not considering safety to be a vital element of a successful business. They still do not understand the most effective way to manage employee safety is to establish a safety system and put it on the front burner right there beside production, quality, cost and all the other vital business elements that must be managed. Many are still wandering from one hot trend to the other in their efforts to find something that results in lasting success. They have a long-standing safety committee that meets on a regular basis, but does little toward reducing injuries. They tried the Safety Training Observation Program (STOP), Behavior-Based Safety (BBS) and all the other fads that came along, finally experiencing about three years of success with BBS until that fizzled and the injuries began to rise again to pre-bbs numbers. What many are not aware of is that programs such as STOP, BBS, People-Based Safety (PBS), etc. are just tools, and certainly not a safety system. They are no more than hazard awareness gimmicks which employers pay tens of thousands of dollars for only to go looking for something to replace them when injuries go back up. They are quite effective for short-term injury reduction largely because of the Hawthorne effect, a phenomenon whereby workers improve or modify an aspect of their behavior in response to the fact of change in their environment, rather than in response to the nature of the change itself. If used in conjunction with a safety system, these programs can be very effective; but, as a standalone concept, they are not intended to take the place of a safety system and are difficult, at best, to sustain for more than 3 or 4 years.

2 Many employers are still of the opinion that employee safety can be managed by turning safety over to someone, anyone, who has the time on their schedule to devote to inspections and training. They still have not learned that everyone is responsible for safety; and, therefore, everyone should be active participants in the safety system. Managing employee safety is not rocket science. It is no more complicated than managing production, quality, finances, or anything else management feels is important to the success of the company. Employers train a worker to do a job, whereby, a near perfect product is turned out and there is no waste. Employees learn and perform the job as they are trained and the company succeeds. Now, just teach them to do the same job safely and hold them accountable for doing it as they were trained. Safety is often managed differently because the worker is not held accountable for safety policy compliance. Why manage anything in a different way? If an employer employs good managers possessing strong managerial skills then why not have those managers apply their strong skills to all their responsibilities in the same way? If they can be effective in managing production, costs, and all else, then they should be able to apply the same techniques to manage safety effectively. But when a manager or supervisor brings a disciplinary action because an employee is late for work, or their work is substandard, resulting in poor quality or production, yet takes no action when an employee fails to lock out equipment or wear PPE, they are not using their managerial skills to manage safety in the same way they do other things. The fact is they are just as guilty as the employee who failed to lockout the equipment because they have failed to assure the worker has done his/her job right and, in so doing, they too have failed to do the job right. Why sell safety short; unless it is because safety is viewed in a different way. The Business Culture How do you establish such a safety system that will continue, year after year, to bring the number of injuries down? How do you manage safety with the same emphasis and effectiveness as everything else? You need to build, not a safety culture, but a business culture that involves employees at every level of the organization. First of all, what is a business culture? A business culture is, a set of attitudes shared by a workforce that encourages everyone to do their jobs right. Doing the job right means doing it right from a production stand point, a quality stand point, a cost stand point and a safety stand point. Someone could be the best widget maker in the company but if he/she refuses to wear the required safety glasses while doing the job then the employee is not doing the job right, regardless of how many perfect widgets he/she makes. And, if the employee s manager knowingly allows this violation rather than enforce the safety rule, then he/she is guilty of poor management.

3 And what is the expected outcome when everyone does their jobs right? Doing the job right maximizes the success of the overall organization by assuring that all elements affecting that success are managed to the best of the abilities of the line organization in order to achieve maximum production (or service) with best quality at minimum cost and no injuries to workers. To achieve success, every organization must do certain things; and, the better they do them, the greater the success. All organizations must: Plan, Organize, Lead, and Control What is it that must be planned, organized, lead, and controlled? In other words, what must be managed? Production (or service), Quality, Cost, Personnel relations, and Safety, among others. Edwards Deming [1], the godfather of quality, held the belief that meeting and exceeding customers requirements is the task of everyone in the organization. He made it clear that quality is the responsibility of every employee at every level. Many companies embrace that teaching as they try to emulate the Toyota Production System. The Deming philosophy was that every employee was a member of the quality organization. The same can be said for production, costs, human resources, etc. Likewise, just as the production, quality and cost organizations are comprised of all workers, since all workers have these responsibilities, so, too, is the safety organization. Safety leaders are just that - they are safety leaders. They are not the safety organization, but are the subject matter experts who provide guidance and consultation to those who make up the safety organization-the employees - just as the quality control manager does for the quality control organization (again, the employees), or the finance director for issues pertaining to cost. It must be made clear that everyone within the organization is responsible for safety, just as they are for providing good production or service without cost over-runs. When we put safety on the same plane as other business functions, and manage it in the same way, then we are on our way to building the culture that recognizes the need to do the job right from all aspects. That is a business culture. Building the Business Culture To build a business culture you first must obtain, not management support, but management commitment. You see, support can be voiced but commitment must be demonstrated and a demonstration of a manager s commitment, by his/her actions, has a much greater impact on workers than anything they may say. If the plant manager truly wants to reduce or prevent injuries then that desire will be demonstrated by his/her actions.

4 Next, get rid of the safety cop. The safety cop is that individual who goes around the plant reminding workers on a daily basis to put on their safety glasses, or constantly pointing out the lockout procedures are not being followed. If an employer has a safety cop, they don t have a safety problem, they have a management problem. If every time you enter a work area you see workers donning PPE or jumping to comply with a rule, then that should be your first indication you have a problem. That tells you that the department management is not enforcing those rules. The only way to get rid of the safety cop is for senior management to express his/her commitment by making it clear that all policies, including safety, will be enforced. Until that happens you will continue to have a safety cop. Next, close the gap that often exists between the workers and senior management. That would be the front line supervisor and the middle managers. They usually will have a vested interest in getting things done faster or better at the expense of safety. Until they understand that shortcuts and non-enforcement will not be tolerated, then the gap will still exist. Establish Ownership. If employees believe that safety is solely the responsibility of the safety manager, they will make little or no effort to identify or report hazards. They will just expect the safety manager or someone on the safety committee to address the issue. To establish ownership you make them a part of the team. You give them assignments, along with training, and hold them accountable. "If an employer has a safety cop, they don t have a safety problem, they have a management problem." This allows the employer to get more people involved in the safety process. This is how it should be. After all, there are countless ways employees can be involved. They can do inspections and investigations. Some may be capable of being good safety trainers. Employees should be involved in safety just as they are involved in production. It should be employees from every level. Many senior managers have embraced programs such as BBS and turned safety over to the workforce, the wrong message to employees. Managers must be active participants. Employers must evaluate their present safety system so they can determine where they are. Unless you know where you are, you cannot find your way to where you want to be. To evaluate the system look at several things, beginning with the metrics. In viewing metrics we have a tendency to look at our incidence rate. That s a mistake because, for several reasons, your incidence rate is not a good measure of your safety system performance. 1. Things happen beyond your control which may result in recordable injuries and illnesses. a. How about 9/11? Nearly 3,000 work-related fatalities in a single day b. Severe weather

5 c. A train derailment near the plant, which releases huge amounts of toxic chemicals; d. Two employees driving to a conference when they are hit head-on by a drunk driver. 2. Recordkeepers typically do a poor job of maintaining OSHA injury and illness records. a. They may be poorly trained; b. They may get inaccurate information from OSHA field personnel; c. They may be pressured by senior managers to keep the numbers low and directed not to record certain cases; d. Recordkeeping is not an easy job. Look at things such as inspections. Are all things being inspected? Look at the findings and the response to those findings. How long does it take to correct the problems, or are there problems not being corrected? Look at past incident investigations to determine what has happened in the past that resulted in incidents and near misses and what was done as a follow-up to reduce the likelihood a similar incident would occur in the future. Get out and see for yourself. What do you notice as you walk through the workplace? Look for unsafe actions and unsafe conditions. Notice if employees are wearing PPE as they should be. Are they following proper lockout procedures? Remove the blinders that prevent you from seeing the trees right there in your own forest. Keep in mind that every employer has not one, but three, safety programs. First, there is the program on paper consisting of all the rules and regulations and the policies and procedures. Then, there is the program we think we have. It is never as good as what is on paper; still we are satisfied for the most part that we have a good program. Finally, there is the third program; what is actually taking place in the workplace. Never assume it is as good as what you think it is, because it is not. Taiichi Ohno, [1] the founder of the Toyota Production System, hailed by many to be the best production system in the world, once said, Data is of course important in manufacturing, but I place the greatest emphasis on facts. And his favorite source of facts was to get out himself and observe. In fact, he used what he called a learning circle. He would take someone, perhaps a young promising engineer, and have him mark a circle on the production floor and stand in that circle for hours just watching. In the book, The Toyota Way, one such event is described in which a young engineer stood in the learning circle for eight hours. Bring in a different set of eyes such as a professional consultant. An unbiased outsider will see things that go unnoticed by those who are in the plant every day. Solicit the thoughts and opinions of workers. What is the employee perception of the safety system? Do workers feel safe when they come to work? Do they have concerns because there never seems to be a response to the issues they bring up? Do they feel free to bring up issues? Do they feel pressure not to report injuries? Distribute an employee perception survey to get a feel for what they think.

6 Ask outsiders such as vendors, contractors, or delivery people what they think. They don t have to be safety experts to be able to tell you when something isn t right or could be made better. Conduct a system evaluation whereby you ask the tough questions. Finally, conduct a thorough audit of all of your written policies and procedures. Look closely at your lockout policy, your confined space policy, hazcom, etc. Are they OSHA compliant? Is compliance enough or should you go further? Next consider OSHA standards. OSHA standards are merely the foundation for a good safety system. OSHA would be the first to tell you that 100% compliance does not result in a safe workplace, only a safer workplace. And for that matter, 100% compliance is not possible. If it were possible you could still have life threatening hazards. Instead of focusing on OSHA compliance, employers should put the emphasis on worker protection. When employers focus on worker protection they will, in many cases, exceed OSHA compliance. Once you ve completed this extensive evaluation and have a better idea where your system stands, you will have a better idea of what must be done to take it closer to your goal. To get where we want to be, that is to minimize injuries, you look at the cornerstones of the safety system. [2] Safety Activities Inspections and Audits Rules and Procedures Fire and Emergency Health and Environment Investigations Education and Training Housekeeping Most employers have historically managed these same issues by way of a single safety committee. The traditional safety committee: is a problem solving committee usually chaired by the EHS manager; meets monthly moving from one project to the next as each is completed; and its success is directly proportional to the amount of authority given by senior management. The problem with the traditional committee is two-fold. First, authority is like gasoline; if you don t have much, you won t get very far; and, safety committees, like safety managers, typically are not given much authority. Second, this still leaves the lion s share of the work to be carried out by the EHS manager. If one were to stop and realize what that entails, then one would quickly realize that unless more people become involved, a lot of that work will not get done. For example, the list of OSHA-required inspections

7 is quite long. Who inspects the machine guards? OSHA requires that all machine guards be inspected every 60 days? Who is the competent person who inspects all the fixed and portable ladders? Do users inspect extension cords, drills, grinders, etc. prior to use on each shift? How do you know if they do? Likewise, the lists of OSHA-required training, required records, required programs such as lockout, confined spaces, hearing conservation, etc., are quite long. Even when these policies are established they must be maintained. If employers rely on a single EHS manager to manage all the things required for a safe and OSHA-compliant workplace, then they may be in for a rude awakening at the next corporate audit or OSHA inspection. A more effective system begins with management participation and, then, increasing the number of employee participants. Such a system provides both authority and increased awareness. Going back to the cornerstones, for each of the eight cornerstones, you establish a team or task group made up of hourly workers and supervisors. Each group is then chaired by a department manager, or whoever is usually sitting around the table when the plant manager holds his/her weekly staff meeting. What does each group do? The Activities Task Group is responsible for oversight of the EHS system. Additionally, this is the creative group. They will develop and organize poster contests among workers or children and grandchildren of workers. They will oversee employee recognition programs for individual employees, sections and departments. They will be responsible for such things as a safety picnic and other opportunities to promote and sell safety. The Inspections and Audits Task Group oversees the inspection effort. They do not do inspections, but instead, will monitor to assure inspections that are needed are conducted and those who do them are conducting them properly. The Rules and Procedures Task Group is to assure that all the required policies and procedures are in place, and they are as thorough as they need to be. As changes occur, for example, new OSHA standards come out which may require new policies and procedures then, this group will make sure the requirements are met by establishing or overseeing the creation of needed documentation. They will update existing policies and procedures as needed. The role of the Fire and Emergency Task Group is to assure that there are procedures in place for any type of emergency that could reasonably be expected. They will oversee evacuation drills, training and maintenance of written emergency action plans. The Health and Environment Task Group will assure that those things related to worker health, or to the environment, have been properly addressed. They are responsible for matters such as ergonomics, respiratory protection, hearing conservation, hazcom, etc. The Investigations Task Group may, or may not, be used to conduct investigations. Most employers who implement this system continue conducting investigations as in the past. The main function of the Investigations Task Group is to assure quality investigations. They will review the completed investigations monthly to assure they have been conducted in a thorough manner, and root causes have been identified, with recommendations for appropriate corrective measures.

8 The Education and Training Task Group manages training. Every employee at every workplace is required to have annual training, some more than others, depending on their jobs. This group determines who needs what training and then schedules the training, along with the trainer and logistics. The Housekeeping Task Group establishes housekeeping standards and then goes through work areas within and outside the plant to conduct monthly housekeeping audits. This group s monthly meeting is usually in the form of a walk-through inspection rather than a sit down meeting. Each member of each task group is given an assignment. This is not a temporary assignment they will work on for a month and then come back for a new assignment. The assignments are permanent for the entire time the members serve on the task groups - usually one year. This will achieve three things: it will make them an expert in these assigned areas; it will improve their ability to recognize hazards; and it will make them safer workers. A member of the Inspections and Audits Task Group, for example, may have the assignment of fork trucks. That individual is not concerned with fork truck training, or operation. He/she is concerned only with fork truck inspections and will become the resident expert on company and OSHA requirements for fork truck inspections. In performing the responsibility that goes with that assignment, that member will collect all of the daily fork truck inspection check sheets completed by the operators for the previous month. They will then take whatever time is necessary, usually about 5-10 minutes, depending on the number of fork trucks there are, to quickly go through the inspections. He/she is looking for evidence of improper or incomplete inspections, repeat findings, indicating the problems are not being corrected, evidence of a need for training, etc. Task group members are not asked to devote a great deal of time to assignments. Just a few minutes each week or month is all that is needed to enable participants to identify problems, and at the same time, increase hazard awareness. Each group, with exception of the Housekeeping Task Group, meets once each month for around thirty minutes. The purpose of this monthly meeting is to allow time for a single member to discuss findings or issues regarding his/her assignment activities. Other issues may be discussed as needed, but the main purpose of the meeting is to cover the progress, or needed attention, for task group member responsibilities. In addition to the eight task groups, there is another group called the Facility Safety and Health Committee. This is a central group comprised of the eight task group chairpersons. This group is chaired by the ranking officer of the facility, in most cases, the plant manager. They meet once each month as well. This monthly meeting is merely a reporting meeting and usually lasts between 45 minutes and an hour. This system, which many EHS professionals will recognize, certainly is not the only way to manage workplace safety; but, it is among the most effective. By establishing this system, an employer now has increased the number of associates, including the plant manager, with active, hands-on participation in the safety process. It is a system that not only puts EHS on the front burner where it should be; but, also, will guarantee a reduction in injuries and illnesses each year, as long as awareness continues to increase. What is critical, regardless of how the safety management process is organized, is to involve as many employees as you can by giving them something to do and holding them accountable; and, assure active participation by the ranking manager.

9 References [1] Liker, J. The Toyota Way. New York: McGraw-Hill, 2004 [2] Taylor, B. Effective Environmental, Health and Safety Management Using the Team Approach. Hoboken: John Wiley & Sons, 2005

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