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CHAPTER 6 ·, 1. '
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SAFETY PROFE:SSION1A·L'S~ AS · CULTURE CHANG,E AGENJS
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This chapter pr~motes the idea that the overarching ~ql~ ~f a s.afety p~ofessional is that of a culture, ~pang~ ~gent. The case 'will, b~ made that every propos~ made by a safety professional for improvement i~ an occupationai safety tp.,anagement system peruµn~ to a deficiency in a system ~r, P.r,oces.~. At;i,d the defi~iency c~n be corrected only if there is a modification in an organization's ·culture-· a modification in the
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way things get. done, a modificc\tion in th~ . syste111: _of expecteq, performance. Thus, the pri~~ role for a ~afety prof es~f 9n~· i~ that o(a c_ult,w-~ change, agent. : .
What does the ~rin overarching me~n? A composi,~ definition, ,as found in dictio- naries, is: encompassing everything; embracing all els~; , including or influencing every part of sometlµng. Thi~ premise-, t~at the pverarching, role , of a safety professional is that of° a ~ulture ~hange agent-applies universally to . ail wbo give advic~ on improving, safety manage~en:t s~ste~s. There are no e~~eptiops. D~finitions of a change agent are numer~:ms. This ~efinition is a co~posite that fits w'ell with the
- • • j ' ' • ·• l safety professional' s position. ' '
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A change agent is a person who serves as c~talyst to bring about orgattjzational change. Change ~geµts ~ .sess th~ present, are controllably ,dissatisfied' with it, conteQ1pla~ a future should ~e, and take action to achieve the culture changes necessary to achiev~ the fut~ . d~sired~ , ·
J'o make th~ cas~ that ~e q~er¥ching rqle of a saf~ty profession~ is that of a ~1.dt~ change agen~, m this chapter f-1.e: · , . . ·
Asqv,anc;d .~~fety M~nag;!"-~nt: ~oc~sin~ on ZJ O Ser j~us' l~ury Prevention econd Edition. Fred A. Manuele. · '
©' 2014 John Wiley & Sohs: iinc. Published 2014 by John Wiley & Sons In ' C.
113
E CHANGE AGENTS
N ALS AS cULTUR
pR()FesSIO
11 4 SAFEiY ithin an organization's overall culture
a safety culture: ·onals affects the culture and ho~
.... rnent on _;, t pro1ess1 . . • Couu•• . ·ven by Sille Y the safety culture 1s negative the advice gt ·fti tties· when . nize the dt cu t to safety professionals as cultur
• Recog s with respec e chan • Pr<>vide resource ll
ents fessionals are cultural change agents ag , ag . that safety pro atnst: Test the premise
• . ents of ztO od 1 c • 'Ibe requirern . "The Socio-Technical M e 1or an Operational . """ provisions 1n Risk
• 1ue ,, Management System
THE SIGNIFICANCE Of MANAGEMENT LEADERSHIP AND ORGANIZATIONAL CULTURE
d th C ulture derive that safety professionals are to influence
From whence oes e • d as tinuous improvement? As management prov1 es the leadership theY
0 pro~ote
3 coonand
3 l) and makes decisions and takes actions directing the orga
(Zl secttons . · . h 1. . · . • th outcome of those decisions estabhshes t e rea 1ty of its safety culture mzatton, e Id b .. as a subset of its overall culture. The outcome con e pos1l1ve or negative. Safety is culture driven, and management establishes the culture.
An organization's culture with respect to occupational safety, environmental safety, the safety of the public, and product safety is determined by the outcome of decisions made by management as measured by the risk levels attained in the technical and social aspects of a facility's operations. The 'culture created by management is the dominant factor with r~spect to the risk levels attained, whether they are acceptable or unacceptable. Over the long term, the injury, illness, environ- mental damage, and property damage experience attained are a direct reflection of an organization's safety culture.
Management owns the culture. An organization'~ culture is translated into a sySfem 0! ~xpected performance. Str.ong emphasis is given to the phrase a system of expected P~ifo,rmance because it defines the staff's beliefs with respect to what management wants done · 1· Alth · d bl safi ty li . m rea tty. ough an organization may issue commen a e
e po c1es, manuals and · h t's expected of th ' operating procedures, the staff's perception of w • 1
expected perf< em and the perfonnance for which they will be measured-its systemef Colleagu::rmarellll~ncde-may differ from what is written. me of h ' · · hat management does hi h avmg written years ago that management IS w
does defines the ~c: li~t maf Y differ from what ·management says. What management n a Y O an org · · , · · · ent or oncommitment to safi aruzation s safety culture and its commttII1 are · ffi. ety. Employee · • • safetY 'me ect, theirrealit R ; . . perceptions of management's pos1non on
To h · y. ehlisttc or u ali • th · tr11thS, ac teve superior nre stic, employee perceptions are elf . :~I direction needed
1 :s~~~; o~Jy top management can provide the Jeade~hl~
in sa~e:~ safety management :bhsh, .~plement and maintain an occupau:~ Y being free from unacystem (ZJO Section 3.1.1). MajoriDIP'°"°!JI tutl
ceptable risks-will be achieved onlY if a cul
fHI: ROLE OF SAFETY PROFESS.IONALS. WITH RESPECT TO 1HE SAF,ETY CULTURE 115
e takes place-only if major . changes occur, in the system of expected ~if ;,mance. That must be ~nderstood by safety professionals in their role as culture change agents. . _.
THE RO~E OF SAFETY PROFESSIONALS WITH .RE~PECT T()THE SAFETY CULTURE
What is the safety profe~sional's role with resp~t to an organiz~tiqn's safety ~µltµre? Assume that safety is a core val_ue in an organization and that the board of c;lirectors and senior management are determined to achiev,e and maintain acceptable risk levels in all operations. Usually, the environmental, health, and safety professionals in those 01ganizations ar~ well qµalified, they have statµre, and the advice they give is well received and seriously considered. . . ·
But even in organizations where safety is . a core val1:1e and superior safety managerp.ent systems are in pla9e, ch~n_ge-favorab.le qr unfavorable-is a constant. Information will be developed through the safety management processes, indicating that improvemeµts can be made in certain safety-related processes.
Then, acting from a sound prof~~fonal base,. the achrice given by safety professionals in their role as culture ch~ge agents is generally welcomed. Their role requires: .
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• Diligent data gathering and analysis to identify the process shortcomings • Proposing arrangements for hazard identification and analyses and risk assessments · to be made
• Giving advice on prioritizing ~~ks . : , • ~ecommeµdtng
I the ,nanagement system_ actions that should pe taken for
tmprovement \ '
But all organizations do not have superior safety management systems. In such entities, the role of the safety professional as· a culture change agent can be ·more difficult, particularly if senior management takes -the position that all is well and believes that there is little need to make changes. The operating base for a safety professional is the same as in the previously bulleted items. . . .
The skill level required to be· a succes·sful culture ch~ge a~ent m such. situa~o~s can be exceptionally demanding. Patience is· required. Sattsfactton ~ay den~e pnnci- Pally from small steps forward. But the goal-remains-th~ same: to a~empt to mfluence the safety culture positively as continual improvement is proposed. . . drifi .
Now, assume that the organization's culture·has always been negattvedordii~ ~ng int th cept of drift nee s , scussion b O a negative state. • I have observed that e con . . ti t expense reductions ecause of the economics in recent years and the sigm can
required by .executive management in some coti~panies. ·Mod ,lling Problem" Jens In "Ri · Society· A e ' R. sk Management in a Dynam,.c ·
asmussen writes: . 1n . . ad'l increasing with a corresponding
e scale of industrial installattons is ste 1 _Y od Ii in a very aggressive I>otential for lar~e-scale accidents. Companies t ay ve ·
. ULTURE CHANGE AGENTS . .-rv pROFESSIONALS AS C
116 SAFc•' . • . • . t which will focus the incentives , of d . . . enviroJUJlen . 1 · . . th ec1s· artd •coinpet1t1ve fi an ial ·arid surviva "Cntena ra et than 1. . ion
jnakers On sMit te:lf;, s~ety and environmental impact. (p, 186~ng !e1Jn criteria concenung
. en attached to RB:Sm~s~~n's pre~se. ~or exan.iple, _in ab Toe word drift ~as _be :tt • to Failure, he cites Rasmussen s work. Delek 1 . 0~kby
Sidney l)ekJ<er enutled Dn.,, Ill • . . . er Wntei: . all t ps This can be seen as decrementalism, where c ,
Drift occurs _1n. stn sdego~ conflicts and uncertainty 'p~oduces small, sten~\vn~n- adaptatton aroun 1 • d , a· . d • ,.· l' tse uous . . f h t was p' reviously JU ge as eviant or seen as viol . ,
nonnal1zauons o w a . . · . . ating some safety constraint. (p. 15)
Wh safety professional senses drift resulting from the ' decisions made th
en a . ,, r k ly al . . at result in "violating some safety constramt or, more i . , sever sa1ety constraints the challenges faced as a cul!ure c~ange agent r~~mre an appr~~~h that attemp~ to deter or slow the pace of dnft. Wit~ the _s~_e_ d~hgent data_gathenn~ _and analysis to identify process shortco~gs and nsk pnontlza~on as m~~ti~hed previously, coun- sel can be given to management on the facts an~ pace of the drift to danger''.
Toe intent is to have management become ·aware that the organization is putting in place the elements ·that increase the potential for a 'large-scale accident' and to encourage that the pace of deterioration in processes be slowed down or stopped. Prioritizing risks and emph~sizing the grq~ing potential for the occurrence of a low-probability/severe-consequence event acquires a high degree of importance.
Safety personnel at locations where the safety culture has drifted into a negative state or the culture has always .been negative probably have to deal with situations in which resources are greatfy limited. · Their communication should provide management with information on which safety-related decisions can be made on a priority basis so that the limited resources available can be applied to achieving the gre~test good. That, again, particularly,· requires priority setting and focusing on preventmg low-probability/~erious-consequence events. ·
. 1 do not claim that achieving success by safety .professionals in such situations :11 be e~y. But the probability of being successful as a culture change agent b ~ced tf 8 safety professional attains the status of an integral member of tlte ~s~ess te~. That will result from ; giving well-supported substantiated, and con·
vmcmg techmcal and m · I · ' rving the bu · · . anagena nsk management advice that is perceived as se smess mterests Admitt dl . · h Id be one of the organi f , · e Y, convmcing management that safety s ou al
skills that saf~:on 'io~ values may be difficult to achieve. A short list of protesslon . pro essionajs should strive to obtain and refine includes:
• A general under~tandin ' . • Use of b • g of business and financial terms and language as1c financial an 1 . • Oral present f a ysis tools such as benefit/cost analysis
• A h a ton and writing skills n en anced ability to infl . . .
• A positive attit d uence business decision makers u e and problem1.solving approach
SELECTED RESOURCES ON SAFETY PROFESSIONALS AS CULTURE CHANGE AGENTS 117
Notice that some of these skills and attributes are business-related. To be successful as an agent of change, the safety professional must operate within the business frame- work in the organi7.ations to which they give counsel.
SELECTED RESOURCES ON SAFETY PROFESSIONALS AS CULTURE CHANGE AGENTS
In 2008, Jim Spigener and Don Groover published a paper entitled "Staying Relevant: The Emerging Role of the Safety Professional-Becoming a Change Agent." They say:
Staying relevant as an organization changes means learning how to leverage your knowledge, skills and experience in new ways. If you are a technical expert in environmental health, and safety, the good news is that you already have the skills and knowledge to contribute to safety strategy. The hard part will be gaining fluency in organizational change ~anagement.
Spigener and Groover write about the core competencies of a change agent, and their comments have a kinship to that ~f other writers. They, and others, say that change agents:
• Are forever inquisitive and never-ending learners • Advance performance by identifying what ought to be, deciding how to get there,
and influencing decision makers to adopt their ideas • Do not leave their expertise behind • Leverage their knowledge and experience to develop strategies to positively
influence actions that result in a higher perforniance level • Recognize that to be influential in achieving change, they must acquire change
management skills ' • Become aware of the culture in place and learn how to manage within it to effect
change • Recognize the effect of management decisions and actions on the culture • Find ways to tactfully inform management when they believe those decisions
and actions may have negative results I ' '
C'1wter 4 in book Safety Through Design ts entjtl~ "Achieving the Nec,essary Culture Change." Steven I. Simon was the author1 Iu, ~pprung pjlfagraph reads as follows:
A full explanatioo of what ~ulture change is and is not, who is _involved, why it · d ~n achieve world class safety .through design, and how to ts necessary an c., · make it happen is provided in this chapter.
Although the foc us of the chapter is on safety through design, it is largely generic with respect to attaining a culture change.
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118 · E CHANGE AGENTS SAFETY PROFESSIONALS AS CULTUR
, ebru 2003 of the magazine Safety Science, there . In Volume 41, Issue l, F d . ~manager as agent of organisational change• 18 an
article e·ntitled "The sa~e~y ~. v;:: Swuste and Frank Arnoldy are the author~ a new challenge to expert tramm5g .· e Group at the Delft University of Technology· are attached to the Safety cienc · ... 111s is the Abstract for their article:
. d "or health and safety advisers/managers· to act There is a great nee l' f h as f h e both in respect to the technology o t e company and the agents o c ang , , . · f h
design of its workplaces, and in the orgamsat10n o t e company health and safety management system. This article reports on the development of training to meet these increasing needs. _The post!raduate masters_ course 'Management of Safety, Health and Envtronment of the Delft Umversity of Technology has now introduced a course-module _of 1 week, addressing the issue of the learning organisation and the specific role of the safety adviser/manager. ·
The course-module starts from the assumption that for a health and safety adviser/manager his or her personal effectiveness and ability to influence and stimulate others are qualities as important to a company as the quality of a safety and health management system. This paper will describe the development in the role of the safety adviser/manager and the mainstream thinking on change management and training. The consequence for the content and programme features of the course-module is presented as well as the results of the evaluation of its effectiveness. ·
For emphasis, we repeat a sentence from this abstract: "The course-module starts from the assumption that for a health and safety adviser/manager his or her personal effectiveness and ability -to infl1,1ence and stjmulate others are qualities as important to a company as the quality of a s~fety an~ health management system."
John Kello, who is connected with Davidson College, had an article published in Volume 6, Number 4, ,of The International Journal of Knowledge, Culture & Change Management entitled "Changing the Safety Culture: Safety Professionals as Change Agents." Excerpts from that article follow.
The Safety Change-Agent
So whihathis th
e proper role of the safety professional in the Total Safety Culture, tow c many · · d te h . 1 orgamzations today aspire? It is definitely not the same 01 it:ti:~Ya ;';fert rt~le,_ even
1 with a broader bandwidth. It is fundamentally, qual-
eren m its approach. In the field of Organ· ti
0 referred to as "ch iza on evelopment, OD practitioners have been ange agents"'from th b · • · · Ii e My central thesis is that h th e very egmrungs of the d1sc1p n ·
be truly effecti · ,thw e e~ they normally think of it in these terms or not, to ve m e fleXJ.ble t b · tion
safety professionals must r£ ' earn- ased High Performance Orgaruza . ' organization developme tpe orm as change agents too. In my view, much m;•
n consultantS, safety professionals encourage and he p
WHY CULTURE CHANGE· INITIATIVES FAIL 119
people make constructive behavior ch longstanding habits and to get out of than~~: to do 'things differently, to challenge
err . comfort zo " Furth the OD consultant, they are almost alw ne • er, and also like . ays more of an influencer than a director.
Kello goes on to say .that "modem safet . . change in their organizations. They, are . y profes~mnals are agents for positive that allow them to effect constructi've· ch trymthrg to bu~ld ,deep working relationships
· · ange ough 1 fl sys~em may not want to change." , · uence'. even when the .client The next reference is not an article or a book I . . . . .
to patient safety that was developed for the U ·s .Dt ts a shde presentation pe~m~g "Change Management: How t A. hi. • ,· · epartment of Defense. The title 1s
. . . · .0 -: c eve a Culture of Safety." . I have tned to avmd mcluding a "how to'' dissertat· . . thi h . · · 1 f th lid. · · , , . ton m s c apter. However as
the ttt e o e s e s~nes says this is ·a how io · - f · k I fir · ·' h
· bel · • . ', . . - P1~C~ o wor . ts st obJective, as s own ow, ts to identify and discuss the . eight step's of h R . - . . . · t J h tt , b k c ange. ecogmtion 1s give~ 0 0 n e~ s 00 as the source of the eight steps, about which mo~e will be said later. Objectives to be achieved are:
• To identify ~nd discuss the Eight Steps .of c .~ange. : ' . • To describe the actions required to set the stage for organization~ change. • To identi~y ways to ~mpo~er team memb~rs to change. • To discus_s what is involved in creati~g ·a new culture. • To begin plannin_g for the chijnge in the organization.
If safety professionals presented this slide series aild attempted to influence others on how to achieve organizational change, they would be serving· as culture change agents. A review of this slide series is recommended for •its informative value.
John P. Ko~r is the author of Leading Change. His book has been well received and critiqued positively. Many authors and consultants refer to Kotter's work; it should be considered foundational. For ,a good and thorou~h r.eview of the conte~t of Leading Change, safety professionals could profit~bly spend some time_ with the slide presen- tation citecf above: "Change Management: How to Achieve a Culture of Safety." Also, as will be·notecf! later, Kotter has a lengthy1paper on the Internet that presents his views. I have been greatly impressed with the thought pattern in Leading Change, a good part of which pertains to what was learned by Kotter from practical applications. ·
WHY CULTURE CHANGE INITIATIVES FAIL
Kotte~ makes it clear that many change initiativ~s fai~. Many other autpors agree and h~ve· pos\ed relative material, on. the Internet. As change agents, saf~W profes- sionals should be well informed on how change 1mt1at1v~s. s_uc~eed ~nd fail and how success and failure are measured. Several references on 1mtiat1ve failures follow.
• A h //E • Art' 1 m/26088 you will find five reasons why leaders fail t ttp: zme 1c es.co to create successful change.
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120 SAFETY PROFESSIONALS AS CULTURE CHANGE AGENTS
. rn/2007/04/seven-reasons-why-organ· . • At http·//andybrazter.blogspot.co · · . . 1sationa1. ·html author presents seven reas.ons why org~mzational ch<Jnge fail change. , an s.
• With the source given as Leading at (t H!gher Leve! by Ken Blanchard, You Will find "Why Change Efforts 'fypically F~l: 15 Pred1ctab~e Reasons & Situations to Avoid" at http://a80.cci.fsu.edu/flabb/www/conference_20l0/round_table documents/Why%ZOChange%20Fail%20or%20succeed.pdf. -
• John P. Kotter has a paper entitled "Leading ~hange: Why Transfonnation Efforts Fail" at http://www.stratafrica.co~~ed1a/:a8f73~cf40110beffff80be 7f000101.pdf. This is a multipage presentation on The Eight Stage Process" to transform an organization. Although the wording in Kotter's paper is not absolutely identical to the content of the book Leading Change, the paper is only a little short of a verbatim excerpt. This is a good and valuable read. Safety professionals are encouraged to download it, as it has significant infor- mational value. ~I
Reflecting on my own experience, a few of the reasons why change_ initiatives fail are recorded here. The first is the most important. ·
' 1. The culture in place and how to work within _it are largely ignored. 2. The leadership and commitment, necessary at sufficiently high levels to
achieve change may not exist in reality because the change agent has not invested the time necessary to achieve the conunitrnent.
3. Decision makers are not seriously enthused about the ch1;U1ge proposed because the supporting data are shallow and not convincing.
4. The importance of becoming aware ·of the power structure and determining · how to work within it have not been sufficiently well recognized. 5. Team buildi~g, which is vital to success, has been inadequate.
6. Preparing for the typical resistance to change at all levels comes up short. 7
· ~ornrnunication to all perso~nel l~vels that wo~ld be. affected by the change
8. 1s not as thorough as needed\ , ·
Management personnel who· are assigned responsibility for the change may ?
0 t ~e held accountable for progress by the people to whom they report, and
m tm~e, the urgency and importance for the change that may have been established diminishes. ·
9. A~~m~tdions are made that a change in a process or system has occurred w1~ klout Setermining· that it has. Others refer to this as declaring victory too qu1c y. ome authors say th h ' h. Id not be
· considered · at a c ange in a system or process s ou in place for ai"1:~ci°°ss as a culture inodification until the chan~e has be: if supervisers allo~ a yehar. Too ~ften, operators revert to previous metbo
sue a reversion. 10. Change agents are not ffi . e rnaY
take several years. su ciently aware that achieving a culture chang
n Ul'\.-:11\J \.lUIUt: l~l A BASIC GUIDE I
The second edition of Environmental 11.,.,111,. .t\, • • · . · . . . iY,~i,ugement .,,.,stems: An Implementation Guide
for Small and Med1um-S1~ed OrganlZllhons was PfeJ)ared by NSF International with funding through a cooperative llgre,ement with the U.~. Environm.~ntal Pro~onAgency. It is o,n the Internet an_d downloadable. Although the text is devoted to environmental management,; many of. its parts are generic. A f~w excerpts follow.
I )lelie~e ~at the contents of the ?~i4e are basic to almost all ch1111ge initiatives. This pul>hcatlen can h!l a good addition to a library titled Safety Professionals as Culture Change Agents. ,
Objectives and Targets: .
. ' Establishing goals for environmental 111,anagement ISO 14001
Objectives and targets h~lp an organization translate p~rpose into action. These environmental goals should pe fact9red into your strategic plans. This. can facil- itate the integration of environmental management with your organization's other management processes.
.. You determine what objectives and targets are appropriate fot your organization. These goals can be applied organization-wide or to individual units, departments or functions - depending on where the impletneriting actions·will be needed:
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In setting objectives, . keep in mind yoµr significant environmental asRCct~, applicable legal and other requirements, the views of interested parties, your . technolq~ical options, and financial, op~rational, and other organizational considerations.
'
There are· no "standard" environmental objectives that make sense for all orga- nizations. Your objectives and targets should reflect what -your organization does, how well it is performing and what it wants .to achieve.
Hints !
• Setting objectives and targets should involve people in the relevant functional area(s). These people should be well positioned to establi~h, plan f~r, and
hi th al lnvolvm. g people at all levels helps to build comnutment. ac eve ese go s. . . · . • Get top management buy-in for your . obJec;tives. This sho~ld. help to
ensure that adequate r~soµrces . are -~pp lied and that the . objectives are integrat~d ~ith other organizational goals. · . . . I . . b' t'ves to employees, try to hnk the obJectives to • n commumcating o ~ec 1 , · · · . · h Id ·
. tal . provements bemg sought. This s ou give the actual envrronmen tm hi 'ble to work towards. .. 1 people somet ng tangt • tent with your overall mission and • M bl b' ti s shoul~ be cons1s
. easqrea e o ~ec ve . ents established in your policy (P.ollution preven- p. lan and the key cormmtm d omplii:1nce). Targets should be sufficiently · · al · ement an c ""'"" · tion, continu lDlprov . ' " ~ !,.J . .. ,.,. nnh113U/3 nn r nh1Pf't1u130 ?" . .
122 SAFETY PROFESSIONALS AS CULTURE CHANGE AGENTS
fl "bl •n your obiectives. Define a desired result, then let the pe 1
• Be exJ e 1 , • oP e "bl determine how to achieve the result. respons1 e . • I
, Objectives can be established to mamtain ClllTent . eve ls of J>erf onnance as 11 as to improve perfonnance. For some environmental aspects, Yo we . b" . u · ht have both maintenance and improvement o ~ectives. m1g . . b" . d
, Communicate your progress in achievmg o ~ectives an targets across the organization. Consider a regular repo~ on this. progress. at staff meetings,
, To obtain the views of interested parties, consider holding an open house or establishing a focus group with people in the community. These activ- ities can have other payoffs as well.
• How many objectives and targets should an organization have? Various EMS implementation projects for small and medium-sized organizations indicate that it is best to start with a limited number of objectives (say, three to five) and then expand the list over· time. Keep your objectives simple initially, gain some early successes, and then build on them.
• Make sure your objectives 311d targets ate realistic. Determine how you will measure progress towards achieving 'them.
A TEST OF THE PREMISE
The source for the following quote is the planning section, section 4 .0 in ZI 0. "The Planning P'°':°'_s goal is to identify and Prioritize oecupational health and safety manage~ent
188 ~• (defined as ·hazaros, risks, management system deficiencies and opporturuttes for improvement)." , ,
The table of contents for ZIO is duplicated here excludi"ng th "S Purpose & A Ii · " • • e cope, , pp cation, section 1.0; and "Definitions " section 2 o R d ked to • . d b . • . . ea ers are as rev,ew every section an su ,Secti,on to consider whether the
1 ·ons
to the following premises. . Y c~ ocate except.I
If hazards, risks and management system deficienci . . . change and improve the relative man es exist, the solution 1s to
agement systems and . f th h SUCCessful, a culture change will have been acbie d A hi : I e c anges are is the ultimate goal. ve · c evmg a culture change
3.0 Management Leadership and Employee Partici atio 3. 1 Management Leadership p n
3.1.1 Occupational Health and Safety M 3.1.2 Policy anagement System 3.1.3 Responsibility and Authority
3.2 Employee Participation 4.0 Planning
4.1 Initial and Ongoing Reviews (Error: For 2012 v . "Review Proeess") ersion, substitute
4.2 Assessment and Prioritization
A TEST IN RELATION TO A SYSTEM TO ENHANCE SERIOUS INJURY PREVENTION
4.3 Objectives 4.4 Implementation Plans and Allocation of Resources
5_0 Implementation and Operation 5.1 OHSMS Operational Elements 5.1.l Risk Assessment · 5.1.2 Hierarchy of Controls 5.1.3 Design Review and Management ofChange 5.1.4 Procurement 5.1.5 Contractors 5.1.6 E~ergency Preparedness
5.2 Education, Training, Awareness, and Competence 5.3 Communication 5.4 Document and Record Control Process ·.,
6.0 Evaluation and Corrective Action · · 6.1 Monitoring, Measurement, and Assessment ,· 6.2_ Incident Inves~gation 6.3 Audits 6.4 , Corrective and' Preventive Actiqns . . . 6.5 Feedbac~ to the Planning Process ,
7.0 Management Review . . 7 .1 Manageme;nt Review Procy~S 7,.2 Management ~eview Outco~es and F~llow-Up
' . . . ' •. ,{
123
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I cannot conceive of a: situation: in which a: hazard, a risk, ·or a man·agement system deficiency exists for ' which the rerp~dy _would ~ot require a· revision in, a process an'.d the system of expected perf o'rmance. If the· process revi~ion is successful, acceptable risk levels will be the result and a culture change will have been achieved. A precau- tion expressed previously needs emphasis: . •E.evisions in a process, and thereby a culture change, should be examined over.time. The purpose is to ~$Ure that:
• Personnel have not reverted to previous practices after what seems to be a success in the short term. . ,
• The modification made is effective in delivering the outcomes expected. • No unintended consequences are created that increase risk.
A TEST IN RELATION TO A SYSTEM TO ENHANCE SERIOUS INJURY PREVENTION
C_hapter 3, "Innovations in Serious Injury and Fatality Prevention", it was said that 018.Jor and somewhat shocking innovations in the content.and focus of occupational risk
m~agement systems will be necessary to achieve additional pro~ss in fatality and ;enous injury prevention." Such innovations were included in my socio-teclutjcal model .~r an operational risk management system. Tiiat model is presented ·here ·in sections to 1
USttate the various levels of approaches to be taken to achieve a cuiture ch~ge.
E CHANGE AGENTS OFESSIONALS AS .CULTUR ,.
124 SAFETY PR f ZlO readers are asked to review each
d ne for the requirement~ 0
s to the premise that if hazards, risks of the As was o ti d excepuon , h . ' or defi . the model to n . dentified, a process c ange 1s necess 1-
e~em~nts _in management systems ar~th1 respect to the manageme~t. system . aryth that c1enc1es m .J, rrnance w1 • th 1 . ' ereb ults in improved pe
110 hanging the culture 1s e \J timate goal. Y res h ge Thus, c bl' hi hieving a culture c an · del pertain to esta 1s ng a sa1ety culture b ac The first two sections of thea°::ent making decisions to assure that the cJ the board of directors and_ to m~. gh d Those sections follow. ture ex ted by the board is estab is e . .
pee d • r management estabbsh a culture fo~ continu ard f directors an semo , d . . . ous
Toe bo O • d fining achieving, an mamtammg acceptable risk improvement that requrres e ' . . . levels in all operations.
1 d hi conunitment, involvement, and the accountability Management ea ers P, hi d · · bl. h th t the performance level -to be ac eve 1s m ac,cord with the system esta 1s a .
culture established by the board.
Changes in policies established at a boa_rd of dire~to~s' level an~. ~pplied by senior management can be achieved if sound, ~~g1~al, convmc~~g presentation~ are made up through the organizational structure. Nevertheless.,, ~at s the managenal level from which an organization's safety culture derives. Havmg culture changes made at the board and executive levels should be the goal of safety professionals. Achieving policy revisions at that level will require superior skills as a culture change agent.
In the model, the next step by ·management is tb establish policies, standards, and procedures to promote ad(?ption of the safety policies set at the board level. Several subjects are listed her~ as a. ~ollection
1 besause they exhibit a similarity-_ a large
majori!)' _of organizations do not h_ave c·oµiparable written processes in place. The next section of the model follows. -
To achieve acceptable risk levels, management establishes policies, standards, . procedures, and processes with respect to: .. .
• Providing adequate resources • ~sk ass~ssme~t, prioritization, and management
Applymg a hierarchy of controls' • Prevention through design :
• Inherently safer design • • Resiliency, reliability, and maintainabilit
Competency and ad . · Y equacy of staff • Capability-skill levels • Sufficiency in numb M. ers .
• amtenance for system . . . • M integrity
anagement of change/pt . b . e-Jo plannin · .
· For most of th £ . , g · be the ex · • e o;regoing, having w · will
ception. Having new syst · ntten ~d established processes in place nt ems establi&hed for. such items as risk assessroe
A TEST IN RELATION TO A SYSiEM TO ENHANCE SERIOUS INJURY PREVENTION 125
prevention through design would be a major undertaking and not easlly achieved. ;aving top-level ski!ls in manage~ent ?f ch~ge would be necessary.
If the elements hsted above became a part of ,an operational risk management stem, it is a near certainty that the probability of serious injuries and fatalities
s~curring would be reduced. That is a good _reason for safety professionals trying to ~pply cul~ur~ change methods to have them ~nstittlte~. : . ·
1
1 '. , . •
Orgaruzauons that employ safety professionals wdl have procedures 1n ·place for most of the following safety-related elements: The exception is "Procurement-· safety expectations." It is understood that getting safety ·specifications included in 'procure- ment orders or contracts is not easy to do (see Chapter'20). "The Procurement Process'·'. Those elements follow: ·' · ' ·
• Safety-related systems • Organization of work · • Training-motivation • Empl9yee p'articip~tion
r
· • lnformation--,--communication ,,, . • Permits - • Inspections • Incident investigation and analysis
- • I Pi:bviding personal protective equipmen,t • 'fNrd-p~ services ·' · , •, R~lationships. with, supplie_rs • Safety of contractors-on premises • Procurement-safety specifications • Emergency planning and management • Conformance/compliance assurance reviews
I
Since improvements suggest~d by sa,f ~tY professionals often are to re6.ne existing systems, the culture change exercise may be easier-. but not necessarily easy. In every case, _the planning, communication, and consideration of people relationships that are a-part of a good culture change process must be at a high level.
!he last element.of the m~del requires periodic performance measurements upon Which sound decisions can be made in support of continuous improvement. That element follows.
Performan9e measurement: Evaluations are made and reports are prepar:ed for , management review to support ~ontinuoQs imprpvement and to assure that acceptable risk levels are maintained. ,., .
th Even at this level, achieving impr~vement in .reporting systems (such ~ -audits) at overlook hazards risks and management system deficiencies requires the etn 1 I I P 0Yment of culture change principles.
I I . ' . J
126 SAFETY PROFESSIONALS AS CULTURE CHANGE AGENTS
CONCLUSION
A sound case can be made in support of the idea that the overarching role of a sat 1 h . . ety Professional is that of a culture change agent. In my ro e as t e map.agmg director c "d 1 •or a safety and fire protection consultancy, it became evi ent ear Y on that the onl
product that we had to sell was advice-: and that our success would be determined/ whether clients believed that our advice provided value. Think about it. Are mo~ safety professionals not primarily providers of advice to achieve change?
Safety professionals are mqst often in staff positions and their role is to provide advice to decision makers on hazards, risks, and deficiencies in management systems so that modifying actions can be taken to achieve acceptable risk levels.
Actions taken to attain acceptable risk levels require culture changes. Although it has been apparent only to a few, safety professionals have always been culture change agents. If they recognize the reality of their role, they should become more competent in achieving changes in systems and processes.
Many big ideas on organizational change have failed because the prevailing culture was ignored. Nearly every author who writes on organizational change makes it clear that achieving permanent change is difficult. Safety professionals must become aware of the importance of giving attention to an organization's existing culture, how deeply certain practices are embedded within processes, who presumes to have ownership of them, and the need to plan and communicate to achieve change.
Safety professionals must be perceived to be members of the management team. Change methods they adopt should, if practicable, be in concert with procedures with which the management team is comfortable so that major conflict can be avoided. A good place to start in applying culture change agent skills is with "Management of Change", Chapter 18 in this book.
REFERENCES
ANSI/AIHA 210-2012. American National Standard, Occupational Health and Safety Management Systems. Fairfax, VA: American Industrial Hygiene Association, 2012. ASSE is now the secretariat. Available at https://www.asse.org/cartpage.php?Iihk=zl0_2005.
"Change Management: How to Achieve a Culture of Safety." U.S. Department of Defense. Available at ~ttp://us.yhs4.search.yahoo.com/yhs/search?p=Change+Management%3A+H ow+to+Ach1eve+a+Culture+of+Safety&hspart=att&hsimp=yhs-att_OOl&type=att_ lego_portal_home. . . ,
Christensen, Wayne and Fred Manuele, Editors. Safety Through Design. Itasca, IL: National Safety Council, 1999.
Dekker, Sidney. Drift into Failure. Burlington, VT: Ashgate Publishing Company, 2011 . Environm~nta.l Management Systems: An Implementation Guide for Small and Medium-Si~ed
Organizations, 2nd ed. Available at http://us.yhs4.search.yahoo.com/yhs/search?p=Envtr~ nmental+Management+Systems%3A+An+lmplementation+Guide+for+Small+and+Med1 um+Sized+Organizations%2C+Second+Edition&hspart=at t&hs im p=Y h~- att_OOl&type=att_lego_portal_home. The copyright is held by NSF International Strategtc Registrations, Ltd., Ann Arbor, MI.
REFERENCES 127
Kello, John. "Changing the Safety Culture: Safety Professionals as Change Agents." The International Journal of Knowledge, Culture & Change Management, Vol. 6, No. 4. Also available for a $5.00 download charge at http://us.yhs4.search.yahoo.com/yhs/search?p=Jo hn+ Kello+Changing+the+Safety+Culture%3A+Safety+Professionals+as+Change+Agent s&hspart=att&hsimp=yhs-att_00l&type=att_lego_portal_home.
Kotter, John P. Leading Change. Boston: Harvard Business Review Press, 1996. Rasmussen, Jens. "Risk Management in a Dynamic Society: A Modelling Problem." Safety,
Science, Vol. 27, No. 2/3, pp. 183-213, 1997. Spigener, Jim and Don Groover. "Staying Relevant: The Emerging Role of the Safety
Professional-Becoming a Change Agent," 2008. It is available at http://www.bstsolutions. com/ /resources/know ledge-resource/ staying-relevant-the-emerging-role-of-the-safety -professional-part-2-becoming-a-change-agent.
Swuste, Paul and Frank Arnoldy. ''The Safety Adviser/Manager as Agent of Organisational Change: A New Challenge to Expert Training:' Safety Science, Vol. 41, Issue l, 2003, pp. 15-27. The authors are attached to the Safety Science Group, Delft University of Technology, Delft, The Netherlands. An abstract of the article is available at http://www.sciencedirect.com/ science/article/pii/So<J25753501000509.
CHAPTER 7
THE PLAN-DO-CHECK-ACT CONCEPT (POCA)
In the Introduction to ANSI/AIHA Zl0-2012, the Occupational Health and Safety Management Systems standard, it is stated that the design of ANZI ZlO encourages integration with other management systems to facilitate organizational effectiveness using the elements of Plan-Do-Check-Act (POCA) Model as the basis for continual improvement. Prominence is given in this chapter to the application of PDCA concepts as an asset in continuous improvement.
Vic Toy, the vice chair for the committee that wrote the ZlO standard, wrote an article entitled "Let Your OHS Management System Do the Work: How the New Zl0 Adds Even Better Value." What Toy wrote also relates to continuous improvement.
The beauty of an Occupational Health and Safety Management System (OHSMS) is that it provides health and safety management in an integrated, interconnected, organic way to maintain focus on continual improvement. The ZlO standard provides a systematic framework and the tools required for continual improvement.
In discussions wjth James Howe, chair of the ZlO committ~e, he also emphasizes that the intent of the committee was to have the application of PDCA concepts be a major influence on continuous improvement. ,
Within Toy's article, which is recommended reading, there was a depiction of the PDCA concept, which includes emphasis on continual improvement. With his
-;--;--_ Adva d , p · S nee Safety Ma11ageme11t: Focusi11g on Z/0 a11d Serw11s Injury revent10,1, ©econd Edition. Fred A. Manuele. .
2014 John Wiley & Sons, Inc. Published 2014 by John Wlley & Sons, Inc.
129
130 THE PLAN-DO-CHECK-ACT CONCEPT (POCA)
,,,,-• __ _ Continual
improvement
,, 3.0 Policy management ,' leadership & employee I
,' participation I ----.., I I
\ Act ' ' 7 .0 Management
review
-- ------------
Plan
4.0 Planning
Check 6.0 Evaluation & corrective
action
mentation ' Do peration ,
FIGURE 7.1 PDCA model. (Reprinted from Synergist, Feb. 2012; with permission.)
concurrence and that of Ed Rutkowski, representing _the ,American Industrial Hygiene Association, 'the depiction' is sh~wn here as Figure 7. 1: . .
To provid~ guidance on the POCA concept and its application in_ problem-solving • • \ I I . • • (; ; ' initiatives, in this chapter _we: · · ·
· l · , :
• Discuss the origin and substance of-the POCA concept. • Comment on the process, systems, and continual improvement aspects of POCA. • Discuss varlatio~s in.POCA appiici tiohs:. ,
, , • ' 1 • !'
• Relat~ th~ ~PCA concept tp basic problem-solving techajques. • Give guidance on initiating a POCA process.
, ', . . . ORIGIN AND SUBSTANCE Of THE POCA CONCEPT
, . .
I : . . ' ·i . . the In Out of the Crisis, W. Edwards Deming provided -a diagram designated as Shewhart cycle. This is what Deming said about it:
The percep~~ of ipe 'cycle shown ~ame from Wa!tet A. Shew hart. I cailed it in Japan in 1950 and onward the Shewhart cycle. It ~ent into immediate. use 111 JaP,an uq9er the name of the Deming cycle so it has been called ever since. (p. 88) I ,, l I , 1 1, , I , , ,
. Deming' became World'.re'ntiwried for !!is su'cCO&kful i,pJiroaches'to quality manhag;; D · ' d · · that! 8 ment. emmg s ep1ction of the Shew hart cycle predates all other diagrams t CA ncep · been able to locate that are comparable to what is now known as the PD co Of
Walter A. Shewhart was ·a Bell Labdratorie& scientist and friend ·and mento~l Deming. Shewhart is c\edited with having developed a statistical process con
DEFINING POCA 131
method in the late 1920s. Thus, the origin of the POCA concept lies in statistical process control, a methodology developed to address the need for improvement in product quality._ . . .
The emphasis m the application of the POCA concept with respect to product quality is on process control and continual improvement. That is also the case in Zl 0. The words process and processes appear in ZlO more than 120 times.
Deming's original depiction of the Shewhart cycle is a six-step, numerically identified process. Following are the six steps as they appear in Out of the Crisis. Keep in mind that this is a quality improvement process:
1. What would be the most important accomplishments of this team? What changes might be desirable? What data are available? Are new observations needed? If yes, plan a change or test. Decide how to use the observations.
2. Carry out the change or test decided upon, preferably on a small scale. 3. Observe the effects of the change or test. 4. Study the results. What did we learn? What can we predict? 5. Repeat step 1, with know~edge accumulated. 6. Repeat step 2, and onward. (p. 88)
The foregoing outline represents good thinking to achieve continual improvement. As Deming wrote, the Shewhart cycle became known as the Deming cycle, and it metamorphosed into the POCA form.
Out of the Crisis was published in 1982. The second edition of Deming's The New Economics for Industry, Government, Education was published in 1994. What Deming referred to as "the Shewhart cycle for learning and improvement" was still close to the depiction of the POCA model in Figqre 7 .1, but one revision was made. Deming referred to his amended model as the Plan-Do-Study-Act (PDSA) cycle. That replacement term-study-has not been adopted broadly. Most of the literature on the continual improvement process refers to the POCA model.
DEFINING PDCA
A variety of descriptive terms appear in the literature on POCA, and safety professionals should adopt the language that best suits their purposes. In the following examples, emphasis is indicated by underscores:
• In Out of the Crisis, Deming wrote that "the Shew hart cycle will be helpful as a ru-ocedure to follow for improvement of any change." (p. 88)
• In The New Economics, Deming said that "the PDSA cycle is a flow dia~ram for learning, and for.improvement of a product or a process." (p. 132)
• On the Internet, a ·paper issued by the North Carolina Department of Environme~tal and Natural Resources is entitled "Plan-Do-Check-Act-A Problem Solym~ fr.ocess." (p. 1)
. y
132 THE PLAN-DO-CHECK-ACT CONCEPT (POCA)
• Th U S Environmental Protection Agency has issued an "hnplementati e .. Pri ·1 ono•
for the Code of Environme_ntal Managemthe~~ I n-dc1p eshfork Federal .Agenc:sd~ They state: "The approach mcorporates e P an o-c ec -act" . emphasis on continuous improvement." (p. 2) and the
• In ANSI/1SO/ASQ Q9001-2008, the American National Standard Q , Management Systems-Requirements, reference is made to "The mode~~ty process-based quality manage~ent system,. and th~ methodolo~ known a 'Plan-Do-Check-Act. (p. ix) This standard gives a bnef but adequate definiti as of the POCA processes, as follows: · on • Plan: Establish the objectives and p(ocesses necessary to deliver result . . ' . s In accordance with customer re,quirements and the organ~zation's policies
I ' •
• Do: Implement the processes. • Check:, Moni~or and measure proce,sses, and product against policies, objectives,
and requirements for the product and report the results. • Act: Take actions to continuallY; imp~oye process performance. (p. x)
So, POCA is a concept, cycle, p~ocedure, flow diagram, process, methodology, and model for continual improvement. To relate directly to ZtO and the work of safety professionals who give counsel on its implementation, the following definition is offered, striving fdr simplicity. ·
The POCA concept presents a sound problem-solving and continual-improvement model.
ON PROCESSES, SYSTEMS, AND 'CONTINUOUS IMPROVEMENT
Throughout Z 10 there is frequent repetition of the premise that "the organization shall establish and implement processes [ emphasis added] to ehsure" that the elements of the OHSMS are established and implemented. The word system appears as often as does processes.
What is a process? What is a system? From the many definitions of process an~ system available, those selected for this chapter are taken from the "Business Dictionary on the Internet. · ·
Process: sequence of interdependent and linked procedures which, at every stage, cons~m~ one or more res~urces (employee time, energy, machines, money) t~ co~vert mputs ( data, matenal\ parts, etc:) into outputs. These outputs then serv as mputs for the next .stage until a known goal or end result is reached. ·
· System: an ~rganiied, P~rposeful ~ttuchire that consists 'of interrelated and interdependent elements (components entities factors members parts, etc.), Th~_se ~!Cments ~~tinu,iuy infl~ence' one aii~ther ccfuect1y or i~dire_ctl~)~: mamtam theu- act1v1ty and the existence of the system, irt order to achiev goal of the system.
ON PROCESSES, SYSTEMS, AND CONTINUOUS IMPROVEMENT 133
The emphasis given to processes is appropriate and important. Having effective processes-manag~ment systems-is nec~ssary in fulfillment of the POCA concept. purthermore, stressing the need for effecuve processes appropriately puts the focus in determining contributing fact~rs. for injuries and illnesses on the adequacy or inadequacy of the processes, that is, the management systems. In accord with the poCA concept, Z 10 is a process standard.
Focusing on deficiencies in management systems is particularly advantageous in an attempt to identify and select the actions to be taken to reduce the probability of incidents or e~posures occurring that may result in serious injuries or illnesse~.
Deming emphasized making system improvements to achieve significant advances in product quality rather than directing efforts on what employees do. In her book Deming: Management at Work, Mary Walton recorded how Deming expressed ·the need to focus on improving the system:
In the American style of management, when something goes wrong the response is to look arqund to blarp.e or punish_ or to search fo~ something to ''fix" rather thap to look at the system as a wlwle for improyemeqt. The 85-15 Rule holds that 85 percent. of what goes wrong is with the system, and only 15 percent with the individ~~ person or thjng. · ·
In applying the -~DCA model, the goal is to improve proc~s.ses. Taken as a whole, the processes make up the manage.µie,i;it _system. In applying ZlO, processes.are to be e~tablished and impl~mented to create an OHSMS. Although ZlO does state tljat "eQlployees s,hall f1SS~~e responsibility aspects of he~l~ and safety over wµich they have. contr~l, including adherence . to ~he organization's health and safety rules," the focus ,o(the standard is on improving proces~es that are controlled by manag~ment. , . . · : _. . \ Each Pi~OC.~.ss is dependeni on the others for the ov~rall managem~nt system to
achieve its goals. In application of the POCA concept, the imp~ct that making a change in one process may have on another process must be considered. Deming addresses the interdependence of systems and processes in The New Economics:
A system is a network of interdependent components that work together to accomplish the aim of the system. A system must have that aim. Without an aim, there is no system. (p. 9~) The greater the interdependence between ·components, the greater will be the need for communication and' cooperation between them. (p. 96) ·
Consider the following as examples.
1. Changes or alterations in the operating system may require: • New job hazard artalyses ' • Revisions in the standard operating procedures • Adj us tments in the content of training programs
l
134 THE PLAN-DO-CHECK-ACT CONCEPT (POCA)
• Rescheduling for maintenance • Extensions in inspection detai_ls
2 Chan°ges in design specificatio.Qs may have an , impact on the safety . . h . d ~related specifications to be included m pure asmg ocuments.
The aim of the OHSM~. in accord with the ~DCA concep_t, is c~e~I~ estahlishe<t· To pro~uJe a manageme~t too~ to reduce the nsk of ?ccuP_ationq/ m1unes, . illnesses· and fatalities. Each continual improvement process 1s an Integral Part of the
8 '
to achfove the desired control of risks ~ To reduce the risk of injuries and illness:s8~ 111 goal in applying every element iri the POCA concept in the continual improve~en~ process must b~ to_ achieve acceptable risk levels.
MEASUREMENT SYSTEMS
A continual improvement proc~s·s requires that measurement , systems be in place to observe progress toward achieving stated ·goals. ·section 6.0 in ZlO, "Evaluation and Corrective·.Action," requires thaf processes· be in place to evaluate the performance of the OHSMS through monitoring, measureinent; · assessment, incident investigations, and audits. Their purpose is to determine whether processes are functioning as designed. The process measurements chosen must be compatible with an organization's siz.e, operations; ·and other measurement' systems in use.
Valid 'statistical· measures such as control charts are convincing and I encourage their rise. ·Jn some situations, _such as · initiating · the culture change necessary to call attention to serious· injury pfevention, the occurrence data on such incidents that would be placecf on a control chart will not'be available since low-probability/serious- consequence events do not occur frequently. Cost data for such events can influ- ential. For an additional reference~ see "Measurement of Safety Performance" in On the 'Practice of Safety, 4th edition. ·
.. :
VARIATIONS ON A THEME
Entering Plan-Do-Check-Act into ~i' search engine on the Internet will bring up thousands of variations of the concept. There are many ·adaptations of the c~ncept ?ecause, through its use, it has proven to be a sound, problem-solving and c?nb•~~; improvement mod,el. Comments are made here on two P.PCA innovatio~s m w,hi , ti . . h · U S EPA s many sa ety practitioners ave an mterest. They are six sigma and the · · environmental management system (EMS). .
S . . . . . 1 I i. service ix sigma is pnnc1pal Y a management strategy used to achieve a product ~r . a defect level of 3.4 or fewer dclects per million opportuiµties, Writers on stx ~•~, refer to the system as a parallel to Deming's POCA cycle. As Deming does 10• 14 Points of Management as presented in Out of the Crisis six sigma empbast~ th · rta f d · · ' . hieve stX e impo nee O es1gnmg processes and systems to enable a staff to ac sigma performance levels. Quoting ftoni Deming in Out of the Crisis:
VARIATIONS ON A THEME 135
A theme th~t appears over and over in this book is that quality must be built in at the design stage. It may be too late once plans are on the way. (p. 49) ·
The s~e principl~ apflies for ~ix ~igma as for OHS~S. In six-sigma programs, the adaptation of Demm~ s ~DCA _is c~lled "Define, Measure, Analyze,' Improve, and Control" (DMAIC). Achievmg a six-sigma quality level is a major accomplishment. How does it relate to occupational injW"Y, and illness performance? . . .
OSHA's recordable incident rate is based on. 2.QQ.,OQO hours wo~keq._ Project th¢ 200,000 base to a million by multiplying by 5. If an organization' naf an OSHA recordable incident rate of 0.68, it would be op~rating at the six-sigma level. Star performers in ~om~ !ndu~tries achieve ·record~ble.i~cide~t r~t~s lower than .0.68. But for most orgaruzations, that performance level !s beyond comprehension. , .
A search for_ easily ijVailable literature on the POCA concep~ that would qe helpful to safety professionals, particularly for smaller and medfom-sized organizations, did
. . , l not r~s1µt in extensive success. However, a publication issued by the Environm~ntal Protection Agency entitled Environmental Management Systems: An Implementation Guide for Small q,nd Medium-Sized Organizations, 2nd edition, is a good reference for more than.one purpose. .. . ..
1. It is a valuable guide. 2. EPA recommends that the envn:onmental _management system :be combined
witµ existing ma,:nag~ment ~ysiems.: In that c~:mtext, referen~e is m~d~ in the text to a Total Quality Manage~~nt System and an Occupational Safety '"'d Health Management System. .
3. The . environmental man~gement system proposed is built on tq~ "m~, Do, Check, Act model introduced by Shewqan and Deming ~d endorse,s the concept
1 • • • , .,, • • I ,
of continuous improvement." (p. 8) . .. . 4. A variation of the PDCA mod~l is includ~d in most of its pages. 5. EPA recognizes the difficulty in ~~hievi~g a culture change and gives good
guidance on the ~µbject _ which is applicable to all . hazard/risk situations. They say:
The EMS approach and an organization~s culture should be compatible. For some organizations, this involves a choice: (1) ta~loring_ the EMS to the culture, or (2) changing the culture to be c~m~atible with the EMS approach. Bear in mind that _ch~~ging an_ o~~ani_zatio~s c~I_ture ~~n- be a long-term process. Keeping this compatibihty issue m mmd will help you ensure .that, the EMS meets1your organization's needs. (p. 9)
6 Th d. · · · t 1· n ·i'tem ·5 have a direct relationship to the institution • e prece mg commen s, , . . of aPDCA system. · ·· . , . .
7 H. t · b · · age 29 c0 r the institution of an EMS are qmte good · m s given, .. egmnmg on p , 1 1 and also apply to the initiation of a POCA system.
136 THE PLAN-DO-CHECK-ACT CONCEPT (POCA)
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all ~ghts unde o limit by this Copyright the farr use of these materials F '.s lot the mtent of NS:t aration of derivative works. Published by NSF lnte~ IQr Use shall not mclude . e prep . Wi b· ww.nsf-isr.org." ationa1: E-mail: [email protected] . w
RELATING POCA CONCEPTS TO BASIC PROBLEM-SOLVING TECHNIQUES
Safety professionals who have an un~erst'.1°di~g of basic pro~lem-~o~ving techniques and how they are applied to hazard 1dentificat1on analy_s1s ~ -d nsk assessments and actions to avoid, eliminate, ~educe, or control ns~s will hav~ relatively eas; time adapting to the POCA concept. Consid_er the alignments of problem-solvin techniques and the Plan-Oo-Chec~-Act idea shown in Table 7.1. The lists· under thg headings "Problem-Solving Methodology" and "Pfan-Oo-Check-Act" are compos~ ites of the methods shown in several texts. ··
In applying either the problem-solving methodology or the POCA concept to prevent injuries and illnesses, the process is as follows. -
1. Hazards are identified and analyzed. 2. The risks that derive from ·the hazardst are assessed. 3. Alternative solutions for risk avoidance, elimination, reduction, or control are · determined in accord with a prescribed hierarchy of controls.
4. Remedial risk management methods are selected and actions are taken to imple- ment them, , I ,
5. Review processes are· to determine whether the desired risk reduction was achieved and whether the residual risk is acceptable or unacceptable.
6. If the residual risk is unacc'eptable, start over.
The only important difference in the literature on the POCA concept in relation to the writings_ on age-old, problem-solving techniques is that more emphasis is given in th
e PDCA literature to the continual improvement of processes. That Zl O is a process, and a continual improvement -standard cannot be stated often enough. Improvements
TABLE7.1
;;:;=:-::=~-::--:-:-----------..,.------- ;Pr;:o: bl;;,e m~-;:S ~o l:::v i:n g::-M=-e th_o_d_o l_o=g y:_ ___ _:P~l an~-D~o-C~~h~ec~k:::A~c t~,:_-------- Identify the problem. Analyze the problem. Plan: Identify the problem. Explore alternative solutions. Plan: Analyze the problem. Select a plan and take' action. Plan_:, D~velop so{µtions. E · h Do: Implement soiutions. xanune t e effects of the actions tak If lt en. Check: Evaluate the results. •~..t
0 ver, resu s are not acceptable start · , • r 'SUII' ------=---.:..:..· =:·.:.:0::;v~er~. _._!_A~c2t:~A~do~p~t~th~e_:c~han~ge:,~ab~an~do~n~tt, 0
INTRODUCING THE POCA CONCEPT 137
in the ~rocesses as the PO~.A concept is appliec;i are to address the OHSMS issues. Those issues are defined m the standard as "hazards n'sks t . . . . , , managemen systems deficiencies, and opportull,ltles for improvement." ·
· Giving due recognition to the emphasis in the standard O p·ocA . ., . . n processes and continua! imp~ovement, I beli~ve nevertheless, that safety professionals who are schooled 10 bas1c pro~lem-s~lvmg te~h_niques can ta~e comfort _in knowing that they need make only mmor adJustments m tl}eir thinking to adapt to the POCA concept. · .
INTRODUCING THE POCA CONCEPT "'
Assume that a safel?7 p~of~ssional wants to take the leadership to apply the POCA concept for an orgamzatlon s safety and health management system. To begin with, an assessment should be m~e of the op)?ortunity for success. After reviewing the situation at hand, the safety professional would bring to bear the technical, small-group leadership, planning, and communication skills necessary to motivate management's buy-in to the POCA concept. The goal is to create strategies for success. There cannot possibly be a one-size-fits-all approach. Consider these extremes:
• The organization has been certified with respect to the. ISO 9000 (quality) and ISO 14,000 (environmental) standards. The management staff is familiar with the POCA concept and
1 w~lc.omes. with enthusiasm the fact th~t the prop9sals
b~ing made to achiev~ continual improvement in, the safety .management sys- te~s are in accord with the POc;A applicaµons in ,other s~and~ds. Even then., a few successful hands-on demonstrations that l~ad to proces~ improve.m~nts related to hazards, risks, and deficiencies in .the safety management system will
J ·' ,1
be ~neficial. • A s~ety, professional is employed in a 500-~mployee QrgaI_1ization in which the
management knows little about the POCA concept .and is resistant to change. That does not preclude the safety professional froJ? framing risk management proposal.sin a way to favorably affect the processes set forth in ZlO and to seek continual improvement in ihose. processes. In that respect, the principles on which POCA is based-good problem-solving techniques-would be applied. Achieving successes in that manner may be convincing and gain the respect of management for the POCA concept.
To moye 'forward in appiying the process and · continual ~p~~ve~ent concep~, change maQagement techniques must ~e brought to bear. The _participation of tecbru- c~lly qualified people in all departments will b~ necessary, and the knowledge and capabilities of the people do~ng the ~orl' should be .~qught. ~elp with respect to change management can be found · in Chapters 6, "Safety Professionals As Culture Change Agents" ~d chapter 19, "Management of Change"· . . . :
The t · • • d rtaking a continual improvement 1rutlat1ve can be as s artmg pomt m un e , • . . ' h d narrow ddr · • t' 1 bazard or as broad as mstallmg a process. t at oes as a essmg a par 1cu ar
I
I·
138 THE PLAN-DO-CHECK-ACT CONCEPT (POCA)
t ) Two real-world indicators of micro and macro not exist (e.g., risk assessmen · appJi. · f th POCA concept follow.
cations o e k mplain that although the standard operating proc .. r1 In the first, wor ers co . h t • b . "UUre
(SOP) requires that they lockout/tagout electnc po~er w_ en a se up Jo. is being done . . . . 1. th distance to the lockout station makes domg so a f m the production me, e b 'Id' une-
. . It is at the opposite end of the u1 mg-a walk of about 40o consummg nwsance. . · · ks . feet They say that the inconvenience promotes taking excessive ns . and !gnoring the SOP and that they have done so unde~ pressure_ to g~t the productt?n line working again. A safety professional is brought mto the d1scuss1on. He looks mto the lockouu tagout design systems throughout the loca~on and ~nds several that are comparable to the error-provocative work situation descnbed by the wo~kers. ~e promotes a meeting of the design, operating, and maintenance personn~l at his location.
• Hazards are identified and the risks are judged to be excessive. • It is agreed that when error-provocative work situations and methods exist, errors
will probably occur, and that in this. instance, ~e injury potential could be a fatality. • A plan of action is agreed upon to study and correct all situations where a lockouU
tagout station is not readily available. . . • Responsibilities are assigned, with target dates for completion. • The plan is put into effect.
It was determined that the action plan achieved its purpose. The risks were reduced to acceptable levels. More important, a recognition developed throughout the depart- ments involved of the fact that hazards and their accompanying risks should be given greater attention fo the design of work systems.
In another multilocation operati"on, a fatality resulting from electrocution occurred in a situation comparable to that just described. The CEO took charge and she quickly recognized that shortcomings in the design of lockout/tagout systems result in unac- ceptable risks and that those risks may be pervasi've. The safety professional was asked to work with operating executives and put together a Plan.
It was -recognized that the electrical hazards had to be identified and corrected. Under the direction of the division vice presidents, each location manager was required to Do, that is, to create study groups consisting of all levels of employment to identify potential electrocution situations, outline ·the actions to be taken to correct them, assign responsibilities and resources, and monitor the actions taken.
Locatio_n managers had to report that a Check had been made to assure that the hazard identification and risk assessment actions had been thorough and that the necessary risk reduction measures have been taken. Furthermore, location managers wer~ expect_ect to Act by providing the necessary resources and demonstrations of lead· ership t? remforce the culture change that had been achieved. It became understood that dunng safe~ audits, all levels of employees would be interviewed concerning the effect of the actions taken.
~oughout this activity, which took several months, the safety professional was avrulable to personnel at the many locations for consulting. He was quite busy.
REFERENCES 139
CONCLUSION
Drafters of Z 10 did well in basing th 0 Systems standard on the POCA con~eptccDup~tional Health and Safety Management 'th th · · · omg so mak th W1 o er mtemanonally accepted standards and .. es e standard compatible
in Z!O with other business practices. facihtates, melding the provisions
Th. e POCA concept is a sound probl . 1 . . em-so vmg and · . with which safety practitioners should be famff conttnual nnprovement model who have knowledge of basic problem-solvin ,ar. Fortunately, those ~ety professionals pJ)CA concept. g methods are well eqwpped to adopt the
REFERENCES ANSI/IS?/ ASQ Q9~1-2008. American National Standard; Quality Management Systems-
Requirements. Milwaukee, WI: American Society for Quality, 2008. "Business Dictionary." Access is at http://www.businessdictionary.com/definition/system.htm. DeIDJDg, W. llclwards. Out of the Crisis. Cambridge, MA: Massachusetts Institute ofTechnology
for Advanced Engineering Study, 1982. Deming, W. llclwards. The New Economics for Industry, Government, Education, 2nd ed. by
the W. Edwards Deming Institute. Cambridge, MA: MIT Press, 1994. Manuele, Fred A. On the Practice of Safety, 4th ed. Hoboken, NJ: Wiley, 2013. North Carolina Department of Environmental and Natural Resources, "Plan-Do--Check-
Act-A Problem Solving Process." At http://quaJity.enr.state.nc.us/tools/pdca.htm. Toy, Vic. "Let Your OHS Management System Do the Work: How the New ZIO Adds Even
Better Value." Synergist, February 2012. U.S. Environmental p,oooction Agency- "Environmental Management systems: An ImpJementa!ion
Guide for Small and Mediutn-Siz.ed Organizations;' 2nd ed. At http:/Jyosernite.epa.gov/wateri owrccatalog.nsfle673c95b J J 602f2385256ae I rmz79fe/7c3822f9d489db0 ! 85256d83004fd7cb!
OpenDocument. U.S. Environmental Protection Agency. "Implementation Guide for the Code of Enviro~ental Management Principles for Federal Agencies (CEMI')-" At http://www.epa.gov/compbancci
resources/publications/incentives/ems/cempmaster. pdf. Publi hi Group 1990
Walton, Mary. Deming Management at Work. New York: Putnam s ng • ·
CHAPTER 8
MANAGEMENT LEADERSHIP AND EMPLOYEE f:>AR,TICIPATION: SECTION 3.0 OF 210 · .. )'
In Chapter 1, "An Overview of ANSIJAIHA Zl0-2005", it was stated that Section 3.0, which addresses "Managem~nt Leadership 'and ~mployee Participation", is the most important section in th~ Occupational He.alth and Safety Managem~nt Systems standard. Having superior management leadership i~ an absolute requirement-a sine qua non-if the goal is to achieve superior results. With respect to this very important section of Zl0, in this chapter we:
• Discuss the significance of management direction as it influences an organization's safety culture
• Comment on the r9le of safety professionals with respect to the safety culture • Set forth the. absolutes needed in managemen~ leadership to attain stellar results • Acknowledge the• impact that the current business environment may have on
achieving or maintaining a superior safety culture • Comment on specific elements in Section 3.o·:
• 3.1 Management Leadership • 3.1.1 Occupational Health and Safe~y Managemen~ System • 3.1.2 OHS Policy • 3.1.3 Responsibility and Authority • 3.2 Employee Participation
d S · us Injury Prevention, Adva,nf:ed Safety Management: Focusing on Z/0 an erw Second Edition. Fred A. Manuele. ., & s Inc @2014 John Wiley & Sons, Inc . Published 2014 by John Wiley ons, ·
141
1
:f
142 AND EMPLOYEE PARTICIPATION: SECTION 3.Q O!= MANAGEMENT LEADERSHIP l10
1 d ship to serious injury prevention • Relate management ea er hi . f. dequate management leaders p and employee Patti . • Descnbe a case o ma h c,p"ion
that resulted in catastrop e . . t mal analysis of the safety culture be made, give an outr
• Propose that an m e case study lne fot such an analysis, and comment on a
THE SIGNIFICANCE OF MANAGEMENT LEADERSHIP AND ORGANIZATIONAL CULTURE
As management provides the leadership (Sections 3 -~ ~d 3 .1) an_d makes.decisions directing the organizatiop, the outcomes. of those dec•~•ons estabhs~ its culture With respect to safety. Safety· is culture driven; and ~anagement establishes the culture. Safety is defined.as freedom from unacceptable nsks. · , . . _
In many definitions of safety culture, terms such as the followu?,g appear: shared beliefs, attitudes, values, and norms of behavior; shared assumptions; in,lividua1 and group attitudes about Jajety; imd entrenched attitudes and opinions which a group of people share. This author has used such terms. Note the frequent use of the term shared which may be inappropriate in some instances.
But such definitions need examination. An -organization's safety culture, a subset of its overall cul~, derives from the deci~ions made at the board of directors' level, at ibe senior management level, and occasionally at a location management level. An organization's culture with respect to occu.pationa! safety, environmental safety, the safety of the public, and produci safety is determined by the outcome of decisions made by management as measured by the risk levels in the technical and social aspects at a facility. The culture created by management is the dominant factor with respect to the ris~ levels attained-acceptable or unacceptable.
Management owns the culture. An organization's culture is represented by the reality of application of its goals, pe_rformance measures, and sense of responsibility to its employees, to its customers, and tci its community-a!! of which are translated into a system of expected performance: Over the long term; the injury and illness experience attained are a direct reflection of an organization's safety culture. . Strong emphasis is given to the phrase system of expected performance because 11 defi~es _what the s~ believes: in reality, what management wants done, Although organJ.Zauons may issue safety policies, manuals, and standl)rd operating proce- d~s,
th e si-:ff•s Perception of what.is expected of them and the performance for
Whic~ the~ Wtl! be measured-its system o/-.,,pect~d performance-may differ from what 1s wntten.
Colleagues remind me of having written Years ago that what management does rathl er than ~hat management says defines the actuality of an organization's ~ety cu ture and its COnunitm t . . th re 1s a d . .cc b en or noncollUnitment to safety Occas1onally, e tuerence etween what ·
'T' hi . management says and what management does. bi'p 1.0 ac eve superior' res · lt 1 - 1 ders d dir . u S, on Y top management can provide the ea d an ection needed to " tabli h . health an es s , unplement and maintain an occupational
ABSOLUTES FOR MANAGEMENT TO ATTAIN SUPERIOR RESULTS 143
anagement system" (3.1.1 ). Major improvements in safety-toward being free safety m cceptable risks-will be achieved only if a culture change takes place-only frotn una .
. changes occur m the system of expected performance. iftnaJor
HE ROLE OF SAFETY AND HEALTH PROFESSIONALS ~ITH RESPECT TO THE SAFETY CULTURE
What is the safety and health pr~fessional's role with respect to the safety c~lture? In an organization where safety 1s a core value and management at all levels walks the talk" and demonstrates by what it does that it expects the safety culture to be superior, the role of the safety and health professional is easier in the role of a culture change agent as he or she gives advice that supports and maintains the culture.
Iri a large majority of organizations, an advanced safety culture does not exist. Then the role of the safety and health professional as a culture change agent has greater significance and requires more diligence as attempts are made to influence management to move toward achieving a superior culture. ·
The possibility of being sli~cessful in that endeavor is enhanced if the safety professional attains the st~tus of an integral member of the business team. That will result from giving well-s~pported, substantial, and convincing risk reduction advice tltat serves the business interests.
Admittedly, convincing management that safety should be one of an organization's core values may not be easily achieved. Safety and health professionals should under- stand that as steps forward are taken by management to improve on management system deficiencies, the result in each instance is' a culture ch'ange. And the requirements to achieve a permanent culture change should be intertwined into each proposal made to improve on a manageinent deficiency. .
ABSOLUTES FOR MANAGEMENT TO ATTAIN SUPERIOR RESULTS
During a review of statements made in annual reports on safety, health, and environmental controls issued by five companies that consistently achieve outstanding results, a pattern became evident that defines the absolutes necessary to attain such results. Elements in that pattern follow. '·· ·
• Safety considerations are.incorporated within the company's culture, within its expressed vision and core values and its system of expected performance.
• The board of directors and senior manageinendead the safety initiative and make clear by wliat they do that safety 'is a fundamental within the organization's culture.
• There i~ a passion for and a sense of urgency for superior safety results. • Safety considerations permeate all busines·s decisic;m making, from the concept st
age for the design of facilities and equipment through to their disposal. 'An ffi · e ective performance measurement system is in place. • All levels of personnel are held ;ccountable for results.
.., 5 -HIPAND EMPLOYE~ PARTICIPATION: SECTION 3.0 OF 2
144 MANAGEMENT LEADEr, 10 . f an or anization-10 employe~s or 100,000-the for .
Whatever the size o. g erior results. Safety is culture·driven and ego1ng prin~iples appl~ to a_chi:~:;ment define the culture aild the syst~m of°; boilr<I of cbrectors an wi::::ere is a passion for superior results, management ins:iectbted ~erformadnced. . k bl ems be identified and resolved. Jlris insistence.by manag s at its hazar an ns pro , . ' . ement at all levels to be informed of the reality of manag~ment system deficiencies is Vita} to achieving stellar results. . . . .
C •
1 ·th superior results demonstrate their ms1stence on having evid ompan1es w . · . . ence-
based management for all purposes, through their conurutm~nt to fin~g, facing, and acting on the facts-no matter how unpleasant those f~cts ~~?t be. That commitment applies to "hazards, risks and management system de1;lc1enc1es, ref ~rred to as "OSHMs issues" in Section, 4.0.
To achieve superior results, management I_IlUSt establish open communications so that knowledge of hazards and risks flo~s upward to decision makers. Proof of management's wanting to know about h~ards and ri_sks is demonstrated by the actions taken to eliminate or control them.
Safety professionals should ~e worl,<lng toward convincing management that it is in their best interest to have processes in place t<;> find, face, and act on hazards and the risks 'piat derive from sys~em s~9i:tcomings. Jet; realism ,with respect to management practices in some companies must be acknowledged. Unfortunately, in actuality, w}\at Whittingham wrote in The Blf!<me Machine: Why HunJan Error Causes Accidents is sometimes true. · · ·
_Organizatio~s, an~ someti~~s wh~le industries, bepome unwillµlg to look closely at the system faults which ,cau~ed the error. Instead the attention· is focused on the individual who made the error and blame is bro~iht into the equation. (Preface)
Readers will not find a statement in this book indicating that the role of the safety professional in favorably influencing an·organization's culture is easily fulfilled. Yet the endeavor is wo~h undertaking, and attaining positive results, perhaps in small steps, can be rewardmg. . ·
THE BUSINESS ENVIRONMENT
It is· possible that the p ·1· . It for safety· pro"'es . al . . revai mg busmess environment makes it. more difficu l 11 s1on s m some or · • . & 0rab Y· Consider th · · gamzations ·to mfluence its safety culture 1av
U~ed fro~~b:::~A fr~m the "Report 0£ the OECD Workshop on Lesso~ Sweden " OECD. • · tha . ccideq.ts and Incident~, 21-23 September 2004, Karlskog d'
. lS e lnt~rnatio al Q · · . · . tion all Development the dire t I n , rgamzation for .Economic Coopera • . bed
, ' c orate of wh · h · · ' . · bhS more than eight years ag th · · · 1~ is .m Paris. Although this report was pu
0 ' e P~~mise cited is still a matter of concern. The concept of "drift" as d fi d . , al performance deterioratin e n~ by Rasmussen as "the systematic organizaU
00 n
g un er competitive · pressure, resulting in operauo
OHS POLICY: SECTfON 3.1.2 145
o'utside ~e desi_g'n' eri~~lop where preconditions for safe operation are being systemaucally vmlated was generally agreed as being a far too common occur- rence in the current business environment. (p. 8)
There ar~ 9t?er ~eforences in the OECD report indicating that the effects of pres- sures to mamtam high profit levels and reduce costs may be among the contributing factors for incidents th~t have low probability but -result in serious consequences. In such .cases, safety requI~meJ\tS may be compromi,~ed and the safety culture deterio- rates. Although the OEC~ report pertains to the chemical process industries~ sfmilar observations are ~ade WI~ respe~t to the nega~ve imp~c~,o.fbottom-line pres,sure.s in other industries. · ·
Later in this chapter we comment on a catastrophe in which management acknowl- edged in its own internally prepared report that its safety culture, over time, was allowed to deteriorate. In Chapter 18, "Le~ ~oncepts ; Emphasizing ~e De~ign Process", reference is made to safety concerns being over ridden as lean concepts are applied. In discussions with sevenµ safety directors, it is,readily agreed that everyone is expected to do more 'Yith less and that bottom-line pressures are weighty . . It is appropriate, the{\, to acknowledge that where tlie business environment results management decision making ~a,t aff~ts the· safety culture _negatively, conv~cing
management that ~afety sho~ld be ·one of the organizatiop's core values will not be easy to achieve,. Jet the safety professional has a,n obligation t9 be professional, factual, and compl~te in the recommendations made to keep risks at an acc~ptable level.
OHS POLICY: SECTION 3. 1.2 . . .. ' ' ' I ,
ZlO says that "th~ . ~rganization's 0
top m~agemen.t shall establish a doc.umented occupational health and safety policy." Appendix A provides guidance. on . what a policy statement should contain a~d provides two samples. An organizatjon's policy ~tatement should be tailored particularly to its p.eeds and written in th~ language that the issuer would · normally_ use. The policy stateµient has to : be beliyva~le. Consideratioq of the f ~llowing · may be helpfu.l when drafting. a poli9y s~t~ment. The policy statement should: '·
,,; '
1. State clearly management's positi~n o~ -safety; .he~th, and _the environme~t, and indicate that avoiding injtJry and illness to e~ployees and to ~e pubbc from operations or from p~oducts sold, as well as damage to the e~vrronment are organizational values.
'' 2. Bear the signature of the senior executive or manag·er. 3 · · 't' ' ' op' erations and their scope. • Be appropriate to the nature of the orgaruza IO~ s 4. Be current reviewed at least annually, and prominently displayed. 5 St ' . . 1 'th all applicable legislation and standards. • ate a comnutment to comp y WI . 6. Affirm that all safety, health, and environmental policies that are m place are
to be followed.
l
146 MANAGEMENT LEADERSHIP AND EMPLOYEE PARTICIPATION: SECTION 3.Q OF 2:10
7. Make clear that emplqyees are to p~cipate a~tively in all elements of t1.. safety and health management system. , . 'lte
8. Pledge to a continual improvement process to reduce risks further.
If additional examples of policy statements are desired, they can be found . safety, health, and environmental reports issued by. comv~nies such as: in the
• Bayer at http://www.annualreport20l l .bayer.com/en/sustainabi1ity-strate . gy,aspx • DuPont at http://www2.dupont.com/personal-protection/en-us/dpt/safety-protecti
- ~ . , , on • Intel at http://www.intel.com/content/www/us/en/corporate-responsibility/env·
mental-health-safety-policy-otellini.html · U'Qn.
RESPONSIBILITY AND AUTHORITY: SECTION 3.1.3
Section 3.1.3 of Zl0 requires that management define roles, assign responsibilities and authority, provide the necessary fosources (financial and human), and establish accountability. If a managemertt accountability system for safety, health, and environ- mental results is not in place, management commitme~t to attaining superior results is questionable. Accountability without consequences is not accountability.
In the Introduction to the standard, it is made clear that it was drafted to be compatible with other business processes. That thought is reinforced in this section. Management is to provide the leadership and assume responsibility for "integrating the occupational health and safety management system into the organization's other business systems and processes and assuring the organization's performance review, compensation, reward and. recognition systems are aligned with the OHS policy and the OHSMS performance objectives." Doing so is a goal worthy of achievement. Getting that done will interweave safety and health processes into and be supportive of the organization's endeavors.
While management has responsibilities for safety, so do employees. As the standard indicates: "Employees shall assume responsibility for aspects of health and safety over which they have control~ including adherence to the organizations health and safety rules and requirements."
Appendix B, "Roles and Responsibilities," provides an excellent reference from w~~h excerpts can be taken to "define roles, assign responsibilities, establish account· ability, and delegate authority" as suitable to an entity's needs. The data cover tbese employment categories:
• President, Chief Executive Officer, Owner
•. ~xecutive Officers, Vice ~r~siden_ts, and other Senior Leadership • Directors, Managers, and Department Heads •. Superviso!s • Employees
• Health and Safety Department.
EMPLOYEE PARTICIPATION: SECTION 3.2 147
Defining responsibilities and establishing accountabilities is an important step. It must be done for safety and health management systems to be effective and to provide a basis for performance and accountability reviews. ·
EMPLOYEE PARTICIPATION: SECTION 3.2
Not only are employees to assume responsibility for aspects of health and safety over which they have control, but they are also to have an opportunity to participate in every aspect of the ~cupational health and safety management syst~m. 1ltey are to, ):lave t}le mechanisms, tune, and resources necessary _to participate. · · · · · · · _
A statement made in the standard's advisory column next to employee piuticipa- tion is close to one that. I have made and believe to be fundamentally true. If an employer does not take advantage of the knowledge, skill, and experience of workers close to the hazards and risks, opportunities are missed to improve safety management systems and reduce injury and illness potential.
Employers improve their prevention efforts if they recognize the creativity of the workers doing the jobs. The purpose of reducing risk is we'll served if the culture makes it clear that the knowledge of workers is val~ed and respected and that they are to participate in the ownership of the safety management system.
Although the provisions in the standard for employee participation are not changed ~ubstantially from the earlier issue:
• Comments in the advisory column are more extensive, including reference to W. Edwards Deming's principles : drive our fear; break down barriers; and eliminate exhortations.
• Contents of Appendix C, "Encouraging Employee Participation," fills about twice as much space as was given to this subject in the earlier version of ZlO. These topics are covered in Appendix C: • Introduction • Organizational Readiness and Effective Leadership • Employee Participation • Other Issues to Consider for Effective Employee Participation • Barriers to Participation.
Extensions made in the advisory material for employee participation are a major change in the standard. The material provided is a good reference source. Two ex~ples of outstanding contributions to risk reduction made by hourly workers come to nund.
In a maker of heavy machinery, the innovations of tool and die ~akers in_ r~e- signing work situations to reduce ergonomics risks were so c~tive that v1s1tors to the plant were often shown their inventions as a matter of pnde.
In a space industry location it became the standard practice for design engineers to seek the opinions of ho~rly workers before proceeding to manufacture what
148 MANAGEMENT LEADERSHIP AND EMPLOYEE PARTICIPATION: SECTION 3 o O · F 2:10
was designed. They learned through expeH~rtce that the suggestions 111
d . .. . 11 h . aeb hourly workers resulted in risk avoidance; particu ar Y· uman factors d , Y
ffi . · h d . es1on errors, and resulted in improved e ciency m t e pro uction process. . Cl
Comments made in the advisory column (E3.2C) on obstacles or battt meaningful employee participation include lack of . response to employ e~s to
· 1· di .. · ee input or suggestions, and repnsals that pena ize or scourage participation. Both of th examples define a negative safety culture. ese
I I
RELATING MANAGEMENT LEADERSHIP TO SERIOUS INJU.RY PREVJ:~TlON
I
My analysis of over 1,800 incident investigation reports indicates that a significantly large sh~ of incidents resultjng in serious injuries and fatalities occurs:
• When unusual and nonroutine work is bei~g performed • In nonproduction activities
• 1 • In at-plant modifjcation or construction 9per.ations (replacing a motor weighing 800 poqnds to .be installed on a platform 15 feet .above tp.e floor)
, • During shutdowns-for repair and maintenance and during -startups • Where sources of high energy ( electrical, steam, pneumatic, chemical) are present • Where upsets occur: situations going from normal to abnormal
It was also determined that:
• Causal factors for low-probability/high-consequence events are seldom represented -in the analytical data on ~idents that .occur frequently. (Some ergonomics-related incidents are the exception.)
• Many incidents resulting in serious injuries are unique and singular. events, having multiple and complex contributing factors that may have technical, operational systems, or cultural origins.
· · · of These studies reveal that often, over time, there had been an accumulauon h . . "' . . made that s ortcommgs m sa1ety and health management resulting from decis10ns
reflected-adversely on the safety cylture. Other writers have written similarly. It , Incidents that result in serious injuries are often low-probability ev7nts tha~~~~s from what James Reason refers to as an accumulau·on of latent techmc~ con . 's
· · · · · uon and operating practices that are built into a system and shape an organiza ate cultyre. He djscusses the long , term impact of a continuum of less-thaµ-adeq~za· man,ag~ment leadership, and dec_ision making in M{l,1?,aging the Risks of Organ tional Accidents, from which the following excerpt is taken.
d. . . detected Latent con 1t10ns, such as poor design, gaps in supervision, un, sy manufacturing defects or maintenance failures, unworkable procedureS, clUID
A CA~E OF INADEQUATE M"f"'AGEMENT LEADERSHIP AND EMPLOYEE PARTICIPATION 149
automation, shortfalls in training, les~ than adeqqflte tools and equipm~nt,- may be present for many years before they combine with local circumstances and actjve f~illlfes to penetrate the system's layers of def~n~e~. · They arise from strategic and othe~ top-level decisions made by gQvernments, regula- tors, man~~acturers, designers and organizational managers. T,he impact of these decisions spreads thrQughout . the organization, shaping a distinctive corporate culture and creating error-producing factors within the individual workplaces. (p. 10)
As the impact of less-than--adeq~ate d~cisiori making_ _by m~nageme~t. spreads throughout an organization, employees at all ievels respond to the 'negative safety culture th1:1t . develops, ~d psky work practices become common. Such a situation, once recognized, presents a challenge to safety-professionals in that giving advice to reduce the probability of incidents occurring that result in serious injuries must become a principal goal for them. -
Although not easy to dq, they mus·t prepar~ data to try to convince management to recognize the possible systemic caus~ factors tha_t have accumulated and take action to reduce them. Thus, to achieve a significant reduction in the potential for low-probability/serious-consequence incidents oc9urring, a different mindset and a culture change have to be achieved. In that respect, safe_ty professionals are culture change agents. · ·
A CASE OF INADEQUATE MANAGEMENT LEADERSHIP I AND EMPLOYEE PARTICIPATION
Data foll~w to illustrate a . &ituation in ~hich det~~oration 'in_· s~.fe~y m~agem~nt leadership and employee _participation resulted in a catastrophic ~nc1dent1 Negative safety decision makjng resulted in a deteriorating safety cul~ure: frulure to adequately involve employees in the safety process,. and poor commuruc~q?n. . -. .
A ·r · ,.;. ty lture' results from .management lea4~r~hzp and direction that posi ive sa.,e cu . . ' - I . t d that "eaders . • d 'b d ·n this case. t 1s sugges e ~-produces the opposite of what is escn e 1 • .
ask whether similar situatic;ms occur in the operati~ns to whic,h they g~v~ co~~se,.
A Catastrophe In Texas City, 2005 . . . 00 d . ort 00 an· incident that occurred on Excerpts are take~ from' an mternally. ~r u~e .. t ep ,- d and · operated refinery. A fire
March 23, '2005 at a BP Products North ~e?ca ~7:xtensive property damage. The and explosion resulted in 15 deaths, 170 mJunes, . t' U,nit Explosion Fihal Report,
. • R port. Jsomenza ion report, Fatal Accident Investigation e ' b 1 Mogford the investigation team Texas City, Texas, USA, was approved for_relea:u ~hich this 'report can be accessed leader and an employee of BP. The website thr g is listed in the reference section of this chapter. t f the report. As the following
Th hi hli hts the conten .o b'li e Executive . Summary g g · · agement leadership, accounta 1 ty, excerpts from it are read, keep the safety c_ultui:e, man · and employee participation implications in mm<l.
150 OYEE PARTICIPATION: SECTION 3.0 OF z10
MANAGEMENT LEADERSHIP AND EMPL
. d tified as follows: [The] underlying causes are t · en
ki nvironment had eroded to one characterized th ars the wor ng e . . • Over eye , d ' lacking of trust, motivat10n, and a sense . t ce to change, an . d
by res1s an led with unclear expectations aroun supervisory of purpose. Cou~ehaviors this meant that rules w~re not consistently and m.anagement 1 k'ng and individuals felt d1sempowered from 11 d rigor was ac 1 . 0 ow~ ' ... ti' •·mprovements. Process safety, operations perfor- suggesung or m1tia ng . . . h d b
t. ·sk reduction pnont1es a not een set and mance and systema 1c n . , . consistently reinforced by management. ·
h. • omplex organization had led to the lack of clear • Many c anges m a c , . . . . . b·l·ti· d p. oor commumcatlon, which together resulted m accounta 1 1 es an • 'b'li · ·
fu . . th wor•,-'-'or.ce over roles and responsi i ties. con s10n m e .lU' . • - • A poor level of hazard awareness and understan?1~g of process s~~ty on
the site resulted in people accepting levels of nsk that are considerably higher than comparable installations. One consequence was that tempo- rary office trailers were placed within 150 feet of a_ blowd~wn stack w~ch vented heavier than air hydrocarbons to the atmosphere without quest10n- ing the established industry practice.
• Given the poor vertical communication and performance management process, there was neither adequate early warning system of problems, nor any independent means of understanding the deteriorating standards in the plant. (p. -iii) · '
A statement in the first bulleted item in the prec~ing excerpts is significant in understanding the positive development of, or deterioration in, a safety 'culture. Changes in a safety cuitute, for better or worse, don't occur quickly. Note that in this situation: "Over the years, the working environment had eroded to one characterized by resistance to change, and lacking of trust, motivation:~ an:d a sense of purpose." The time. element is further ·recogni~ed as follows in the Executive Summary.
' It _is evid~nt that [the causai'factors] had been many years in the making and will require concerted and committed actions to address. (p. iii)
1 Th~ autbors. _of 19-e report {~ogpized that, reversing the cultural trend will take a
ong ttme,,cons1denng tl}e nature of the recommendations made. They pertain to:
• People and procedures • Con_trol of work and t~ailer citing • Design and engineering (p. iii)
The following excerpts were tak fr if- icall y to inadequate Particip f b en om the body of the report. They relate spec t culture that accepted high ri a~o~y the hourly workforce, poor motivation, a safel~
s t ng, and the failure of senior management to ho
PROPOSING AN INTERNAL ANALYSIS OF THE SAFETY CULTURE 151
people accountable for following the "defined processes/procedures." For emphasis, we repeat: This is an internally produced report by BP personnel.
• There was a failure by leadership to hold employees at all levels accountable for executing defined processes/procedures. A workplace environment character- ized by poor motivation, unclear expectations around supervisoryimanagement behaviors, no clear system of reward and consequences, and high distrust between leadership and the workforce, had developed over a number years within the site. The working relationships· between leadership and workers, and employees and contractors were poor. (p. 153)
• Specifically, the team observed that the relationship between operations and engi- neering was inconsistent and fractured; evidence of this was the fact that engineering was not called during the startup problems; nor did the team find evidence that engi- neering rounds were being .conducted. In addition, the _ "independent" functions, such as training and Process Safety Management, had become under-resourced and lacked the influence to ensure that standards were met. (p. 166)
• The fourth cultural issue is the inability to see risks and, l)ence, toleration of a high level of risk. This is largely _due to poor hazard/risk identification skills throughout management and the workforce, exacerb~ted by a poor understanding of process safety. (p. 167)
To describe a positive safety culture that results from good management leadership and employee participation, start.by turning the negatives ,in the foregoing into affirmatives.
PROPOSING AN INTERNAL ANALYSIS Of THE SAFETY CULTURE
Assume that management responded favorably to a suggestion made by a safety professional that an internally conducted s~ey of the orga~ization's safety culture would be beneficial. The purpose would be to gather the perceptions of all levels of employment on the quality of the safety management system iri place. It should be understood that for those who participate in the exercise, their perceptions are their reality. The result of such an exercise will be a culture survey. ·
The self-analysis provides data on the positive and negative effects of mana~ement leadership, the extent of employee participation, and whether an accumulation has developed ·of latent technical conditions and operating practices that could be the causal factors for low-probability incidents h~ving severe consequence_s. .
For such a self-analysis, a survey mechanism is necessary. An outline o~ a b~s1c survey guide follows. For the survey mechanism to rel.ate to the hazards and ns~s m a Particu!ar operatio~, it i~ necessary that manageme~t, assisted by a s_af ety ~rofess10~al, add or delete items. Also, a scoring system for each item, c?~patible Wl~ practices app!ica~le in the organization, shou~d be included _in ~e rev1s1~n of~; gu~?~, so .~at a compilation of results can be made. In many situations, a simple yes, no, or "not applicable" scoring system will' suffice. It must be emphasized-this guide is not offered as a one-size-fits-all mechanism.
11
152 p AND EMPLOYEE PART191PATION: SECTION 3.0 OF z
MANAGEMENT LEADERSHI · • 10
Safety Maqag~ment System S<urvey Guide . . . · , ent system in place m our, orgamzat10n effective?
I Is the safety managem . . · · t demonstrate by what 1t does that safety 1s a core v 1 2. Does managemen · . , . a ue in our organization? . . . : .
. th. . 'ficant gap between what management says and what manag 3. Is ere a s1gm · ernent
does? . · · 4 H th taff rep
orting directly to the semo~ man_ ager been h~.ld accountabl . . as e s . . aki ? . e, 1n reality, for a high level of safety decision m ng .
5. Is this a safe place to work? 6 . Are you asked to participate effectively in safety discussions and meetings?
7. Are you asked to provide input on safety matters that affect you directly? 8. Is your input ·on safety matters respected and considered valuable? 9. Do you ·believe that sonie of the equipment you operate or the work methods
you are required to follow are hazardbus br ovedr risky?_ . 10. Do you believe that you are free to report b'.azardous conditions and practices
without reprimand? ·· · · 11. Are you encouraged to report hazardous conditions an~ practices? 12. Does y~ur supervisor effe·ctively give safety a big~ priority? 13. Is accident investigation in sufficient depth to identify the reality of causal factors . (orgaI)izatiopal, cultµral, design and engineering,technical, .procedural)?
14. Is there a broadly held belief that unsafe : acts of , workers are the principal causes of accidents?
15. Is safety often relegated to a lower status and overlooked when there are production pre:SSUres? ' l ' '
16. Have you been given adequate training on hazards, risks, and safe operating procedures? · '
17. Does the organization's· culture accept gradually escalating risk? 18. Does the organizational structqre ·enhapce ~r _dissuade adequate safety decision
makirig? · · · 19. Are there org·anizational barriers . tQat prevent effective c~mmu~ication on
, safety, up and down? 20, · Hay~ strea:zniining and downsizing.~onveyed a.~essage th~t efficiency and being
)( on schedule are paramount, and that safety considerations can be overlooked? 21 · Is , staffing adequate in your group adequate •so that work can be done safely? 22: Are: you discouraged from reporting injuries? . 23· ~av~ techpical an~' operational safety standards been ~ta sufficiently high level? 24. ~as, it been the ~ractic'e to accept ;safety performance 1 ~t a lesser level than the . S~dard Oper~tw:n Procedures prescribed? _ ,, 25. Have kpown safety probl~~s. over time, been"rei~g~ted t~ a "not of co~cern
status and, ttiereby become "acceptable . k "? . 26. Has safety-relatea'bardware or ~oftware ::c:~e obsolete?
CASE STUDY 153
27. Are certain operations continued with the -knowledge they are unduly hazardous? 28. · Have budget constraints had a negative effect on safety decision making? 29. Has inadequate maintenance resulted in an accumulation of hazardous situations
that have gone unattended ( e.g., is the detection equipment adequate, maintained, and operable; are basic safety-related repairs postponed unduly)? ·
30. · Has adequate attention.been paid to "near miss" incidents that could, under other circumstances, have resulted in a major accident? ' ·
· 31. Are safety personnel encouraged to be aggressive when expressing their views on _hazards and risks, even though their views inay differ from those held by others?
32. Has there been an overreliarice on outside contractors ( o~tsourcing) to do what they cannot do effective~y with respect to safety?
33. Are purchasing and contracting procedures in place to limit brii;iging hazards into the workplace?
CASE STUDY
A safety director in a very large orgal_lization with about 13,000 employees read an article of nune in which emphasis was given to the necessity of having a positive safety culture to achieve superior perfoimance levels. That organization's work is con&idered "l_righ hazard", and fatalities an~ serious injuries occur.
Th~.safety. director had concluded that the senior _executive ip his organization,. to whom he reported, was somewhat removed from the leadership necessary to reduce fatalities ~d serious injuries and tha,t µe did not hold the staff reporting to him accountable for their incident experience. •
The safety directgr squght help. Dupng our discussions it was agreed that -Jie would approach his boss to convince him that the organization would be well served if the opinjon~-of .the staff were solicited on the quality · of the safety management system in place. fie did so, and it worked.
A Safety Management System Survey Guide comparable to that shown _pre".'iously was sent to the safety director. He worked up a version of it that fit the high-hazard operation with which he is involved. The survey gui~e was sent ~o a statistically actequate sampling of the staff at all employme,nt levels. Over 70% of those who received of the survey guide responded. _They took the sl,lfvey seripusly. , . . When the safety director analyzed the res~J~, he found that the saip.e shortconungs m the safety management system were recorded, largely, by all. levels of employment; and there were many shOJ;tcpmings. ~ut most ,important, some of the ~taff members r~porting directly to the senior executive who
1 3:uthorized the survey said that for the
dep'lrtment as a whple, safety was not a high-level value. . . During a meeting that I attended with the safety director,. his boss,_ and other mter-
ested . persons the . senior executive was well prepared .with questions about how superior safe~ re~ults were achieved elsewhere. He was surprised by the results of the culture survey. He learned that every level of the ' organization sajd that they wanted safety to be given a highe~ status.
1JI
,:
p AND EMPLOYEE PARTICIPATION: SECTION 3.0 OF 210 154 MANAGEMENTLEADERSHI
. d . 1 asked the senior ;executive to draw an org . As the discus~mns _proc_eede .'tion and showing the positions of all who re aniza,
tional chart startmg Wt!h ': ~.:«ige that if he wanted risks of injury and fatJtte<1 to,him. He was qwck tohac ot:provide the leadership and hold the staff reporte~ to be reduced, he would ave · 1ng
to him accountable for ~ul~:.Cutive convened his staff and laid out what he ••Pee Subsequently, ~e sem?r e ed throughout the organization setting forth the sa4'.'ted of them A bulletin was 1ssu . . tety . · d the rocedures to implement it. Safety 1s now ~n agenda item for several
pohcy anf p nt meetings · division heads are holdmg the staffs reporting t levels o manageme • : · . . . o them accountable for results, and man, ~ement is encouragmg mput and mvolvernent from all levels of employees. . .
Communication has improved downward and upward. Safety-related suggestions get quicker attention than formerly. ·
CONCLUSION
Management Leadership and Employee Participation is the most important section in the ZIO standard. Safety is .,culture driven, and leaders create the culture. It is the responsibility of leadership to change the safety culture when it is deficient.
Top administrators must take responsibility for risk management by remaining alert to the effects their decisions have on the work system. Leaders are responsible for establishing the conditions and the atmosphere that lead to their subordinates' successes or failures.
As top management makes· decisions directing the organization, its safety culture is established and that culture is translated into a system of expected performance. Where safety management systems are most effective, there is a commitment to:
• Find the facts about hazards, risk, and deficiencies in management systems; regardless of any unpleasantness that may arise in the discovery process
• Take actions to achieve acceptable risk levels
. ·A safety culture is unsound if employees do not have opportunities to participate m every aspect of the occupational health and · safety management system and if tbey do not have the mecharu' sm ·ti· d . . re . f S, . me, an resources necessary to participate. Furthermo ' 1
an employer does not take advantage of the knowledge skill and experience of :~~t>tirers clo~e to the hazards and risks, opportunities .;e mis~ed to reduce injur)' . 11 ness photential and for improvement in safety and health management systems.
oo muc cannot be made of th · . . • ks be at acceptable levels Parti 1 1 . e importance of concentrating on havmg ns the WO k ts d ' cu ar Y at what James Reason calls the "sharp end," where r ge one.
In Section 4.0, the planni . · · · ted of management and em lo ng section, Z_I O provides a focus for all that is expec . al health and safety man!ge~ee•; _The planmng Process goal is to identify occupatto:nt system deficiencies and O en issu~~• which are defined as "hazards, risks, managem
' PPorturuties for improvement." .
REFERENCES 155
Consider this premise: The entirety of purpose of those responsible for safety, ardless of their titles, is to manage their endeavors with respect to hazards so that reg
the risks deriving from those hazards are at an acceptable level.
REFERENCES
ANSI/AIHA Zl0-2012. Occupational Health and Safety Management Systems. Des Plaines, IL: American Society of Safety Engineers, which is the secretariat. Available at https:// www.asse.org/shoponline/products/Z 10_2005. php.
Bayer, for a safety, health, and environmental report. Available at http://www.annualreport 2011.bayer.com/en/sustainability-strategy.aspx.
DuPont, for a safety, health, and environmental report Available at http://www2.dupont.com/ personal-protection/en-us/dpt/safety-protection.html.
Fatal Accident Investigation Report, Isomerization Unit Explosion Final Report, Texas City, Texas, USA. Date of accident: March 23, 2005. Date of report: December 9, 2005.Approved for release by J. Mogford, investigation team leader. http://www.rootcauselive.com/Files/ Past%20Investigations/BP%20Explosion/texas_city_investigation_report.pdf.
Intel, for a safety, health, and environmental report. Available at http://www.intel.com/content/ www/us/en/corporate-responsibility/environmental-health-safety-policy-otellini.html.
Manuele, Fred A. On the Practice of Safety, 4th ed. Hoboken, NJ: Wiley, 2013. Reason, James. Managing the Risks of Organizational Accidents. Burlington, VT: Ashgate
Publishing Company, 2001. "Report of the OECD Workshop on Lessons Learned from Chemical Accidents and Incident,
21-23 September 2004, Karlskoga, Sweden." Paris, France: Organization for Economic Cooperation and Development, 2005. Available at http://www.oecd-ilibrary.org/economics/ oecd-series-on-chemical-accidents-no- l 4_oecd_papers-v5-artl 5-en.
Whittingham, R. B. The Blame Machine: Why Human Error Causes Accidents. Burlington, MA: Elsevier-Butterworth-Heinemann, 2004.
CHAPTER 9 ·, .,
i '
')
. '
PLANNING: SECTION 4.0 OF.210 'i I
In the Plan-Do-Check-Act model, the purpose of the plan •step is to identify and ana- lyze problems. Establishing and implementing the processes set forth in the planning Section (4.0) of ZlO will serve problem identification•and analysis purposes as well as to develop solutions and implementation plans with ·respect to the problems identified.
As is said in the standard, the "planning process goal is to identify and prioritize occupational health and safety management system issues." Those issues are "defined as hazards, risks, management system deficiencies, and opportunities for improvement." Also: objectives are to be. established that offer the greatest opportunities for improve- ment and risk reduction; occupational health and safety issues are to be prioritized; and plans are to. be formulated to accomplish the prioritized objectives.
REVIEW PROCESS: SECTION 4.1
!his ~ection states tlrat the· organization shall establish continuing review pro,cesses to identify the differences between the safety and health management systems in place and the requirements of Zl O. This statement, in E4.1A, provides significant guidance on what is expected. System reviews are focused on -manag(!men.t systems and are not specific to operations. Note the emphasis 011 manag~ment ,systews. Whily the_reviews are "not specific to operations," hazards and risks in operations may indicate that lbete are shortcomings in management systems that need review. the Thes~ system reviews will .fajfill the problem iden~fir.ation _Md ana,ysis ~teps and
solution consideration steps of the POCA concept. Information gathered on hazards,
A~ '' ' dvanced S ,-r. • • Second . t:yety Management: Focusing on ZJO and Serious fnJury Prevention, © 20l Edition. Fred A. Manuele. 4 John Wiley & Sons, Inc. Published 2014 by John Wiley & Sons, Irie.
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f: 1
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158 PL.ANNING: SECTION 4.0 OF Z10 •
ement systems 1s to be ~alyzed to Prov·ct . . safety manag . . . 1 e risks and deficiencies m 'd ed by an orgamzation as 1t creates "the Proc a. ' . . b e to be cons1 er ,, esseg decision and pnonty as . 4 'ts management systems. necessary to establis? or unprove ! to be supplemented by information arising fr
The ongoing review ~roe~~ :e standard, such as "Management Leadershi om. application of _o~er_ sec,?~;s \ementation and Operation," "Evaluation and Corr~~nd Employee Parttc1pat1on, mp . ,, Ve
. ,, d "Management Review. . . Acaon , an . al un· provement information is to flow to the dee· . fi ard on contmu ' 1s1on
To move orw 1 ts in the safety and health management systems can be akers on how the e emen li hth ed fth ?1 led flow is necessary to accomp s e ne s o e managern.e 1IDproved. That know ~e . nt
review process outlined m Section 7. . . . For the planning section to be accomplished successfully, an orgaruzation tnust
demonstrate by its culture-dts system of expected peiforma_nce-that ma~agern.ent is committed to being.informed on the facts about hazards, nsks, and deficiencies in its safety management systems, r~gardle~s of any _unpleasantness ~hat may arise in the discovery process, and to taking actions to achieve acceptable nsk levels.
Since very few organizations meet all of the requirements of Zl 0--a state-of-the-art standard-it is a near certainty that shortcomings in existing systems will be identified. The result should be prioritizing the shortcomings and developing action plans to improve the existing safety and health management system.
For the review process, the standard suggests taking into consideration: the relevant business management systems; hazards, risks, and controls; allocation of resources (funding, personnel, equipment); regulations and standards; assessments; and other relevant activities.
SHORTCOMINGS EXPECTED IN THE REVIEW PROCESSES
When ~akin~ the reviews required by this standard, it is suggested that particular emph~is be given to those processes in Section 5.0, "Implementation and Operation," for which most organizations will be found wanting. Those processes include:
• Prevention through des· h · h · 1 • . . ign~ w _ Ic ip.c udes ~afety design reviews Risk assessments and prioritizatigµ
• Managementofchange • A prescribed hierarchy of controls , • Safety specifications bein in 1 . . . .
, g c uded m purchasmg documents
ASSESSMENT AND I ~RIORITIZATION: SECTION 4.2
This section requires that processe . . health and safety managem t . s.,~e I~ place to assess and prioritize the occupau~nal processes. The intent is to "en issues _identified in Section 4.1, the ongoing review
assess the impact on health and safety of OHSMS issues
ASSESSMENT AND, PRIORITIZATION: SECTIO~,4.2 15~
d assess the level of risk for identi.fied hazards" and to "establish priorities based an factors such as the level of risk, etc." . . . on In addition, the processes shall "identify the underlying caµses and other contrib- uting factors related to system deficiencies that lead to hazards and risks." As the "system deficiencies that lea? to ~azards and risks" are identified and planning is begun to yliminate them, cons1dera~on must b~ given to the probability that the system deficiencies define safety culture madequac1es. If so, culture change mechanisms would be utilized. . 1 . : ,
Section 4.3, "Objectivest and Section. 4.4, "Implementation Plans and Allocation of Resources," logically follow the assessment and prioritization requirements. They require, principally, that processes be established and implemented to:
• Set documented objectives based on the priorities developed with respect to the hazards and risks identified and the shortcomings found in the safety and health management system (Section 4.3).
• Establish a documented implementation ,plan to achieve those objectives. That plan is to define resources, responsibilities, time frames, and appropriate measures of progress (Section 4.4).
• Allocate resources to achieve the objectives established (Section 4.4).
The goal of the risk assessment and prioritization process is to provide input for decision makers as they attempt to attain an occupational environment in which the risks are judged to be acceptable. Safety:professionals must recognize the real world of economics' with respect to resource · allocation · and setting priorities so as to achieve the best probable good from the · expenditure of those resources. In that context, prioritization needs special comment.
• Some risks are more significant than others. • Usually, significance is determined judgmentally through a review of estimates
made of the probability of event or exposure occurrence and severity of outcome potential.
• Safety professionals must be capable of distinguishing the more important from the less important.
• Resources will always be limited, and staffing and money are never adequate to attend to all risks.
• The greatest good to employees, to employers, and to society is attained if resources available for risk avoidance, elimination, reduction, or control are applied effectively and economically.
• On a priority basis, consideration is given, first, to those risks that have the greatest potential for serious harm or damage.
Although Appendix D, "Planning-Identification, Assessment and Prioritization" (Section 4), is of general interest to all organizations, it begins with guidance to entities th
at are implementing a formal occupational safety and health management system
160 PLANNING~ SECTION 4.0 'OF 210·
for the first time. It is suggested that such en~ti~s Perform a_ baseline or gap anaiy,; 'th 'd tt'fi diftierences between the requirements of this standard and an·y s ' at 1 en es . - . . , Pre.
existing management systems." · , . . , . . H. 1 . • on the procedures to be followed and the mformation to be gath e p 1s given . . . . . . erect
and reviewed to identify occupational safety and healt_h ~~na?ement system needs G . 'dance comments are provided oh assessment and pnont1zat1on factors and syste ·
ll1 . ,. , Ill and operational issue examples. ''. · ,, ' - . · · · . · Appendix E, "Objectives/Implementation Plans (Secti~ns 4.3 and _4.4), provides
reference material on managing·safety and health ·and planrung and setting objectives This appendix includes a helpful outline'for "Managing Safety and Health: Plannin~ and Setting Objectives." 1 ,. • · '
CONCLUSION
Success of an occupational safety and health management system is largely contin- gent on how thorough the provisions in the planning process are applied. They are to identify and prioritize the issues, which are "defined as, hazards, risks, management system deficiencies, and opportunities for improvement." As that process moves forward, it should be understood that the entirety of purpose of those responsible for safety, regardless of their titles, is to manage their endeavors with respect to hazards so that the risks deriving from those• hazards are acceptable.
This planning section requires that shortcomings in existing safety management systems be identified in relation to the requirements of ZlO. Existence of hazards and risks is evidence of system shortcomings. -Once those inadequacies are known, pri?rities are to be set, objectives are to be established for improved risk control, and actions are to be outlined in a documented plan for continual improvement. Those processes represent good management as resjlects applying the PDCA concept.
.,.
CHAPTER 10 ·
IMPLEMENTATION AND OPERATION· SECTION 5.0 OF 21.0 ·
I ,
INTRODUCTION
,,
Provisions in the planning section of Z IO (Section 4.0) pertain to the first three ste s m the Plan-Do-Check-Act'(PDCA) process: ·• · p
Plan: Identify the problem. Plan: Analyze the problem. Plan-:. Develop solutions. Do: Implement solutio·ns. Check: Evaluate the results. , Act: Adopt the change, abandon it, or start over.
. In thci planninl; proceSses, occupational health and safety management systems issues are identified, analyzed, and prioritized. Those issues are defined in the
st andard as hazards, risks, -management system deficiencies and opportunities for
improvement (italic type is used for material taken directly from the standard). After the identification and analysis process, objectives are then to be established
th at off er the greatest opportunities for improvement. The following steps are to
draft a documented implementation plan to allocate th,e necessary resources and to
. As the Implementati~n and' Operating section of j':10 is applied, the activity moves achieve the .objectives. into the "Do" 'element of the pDCA process. rlie standard says that this section [5.0] '
Advanced Safety Management: Focusing on ZJO and Serious Injury Prevention, Second Ed'· · 1t1on . Fred A. Manuele. . r ©
2014 John Wiley & Sons, Inc. Published 2014 by John Wtley & Sons, Inc. 161
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secr10N 5.0 OF z10 ND OPERATIO :
IMPLEMENTATION A 162 quired for implementation ofan OJiS'A"
t that are re S nd h ~r1.S defines the operational e::Je~he backbone of ~n OHSM a , t e. means to PU~sue and that these elements p . . rocess. h bjectives from the pla?mng p thi "Do" element. Although all the sections in Zlo
t epo articular emphasis is given to his . ng an effective safety and health managetn. 'th ect to ac evi . . S . ent have significance wi resp . d operation requrrements m ection 5.Q ha
system, several implementation ~e standard says, the backbone of an occupationv~ articular significance. They are, as a
p gement system. bl' hi . health and safety ral uidance with respect to esta is ng an impletn.ent-
Section 5.1 provides gene fg -~ety and health management system, and say ti nal elements o a s'"' . h s ing the opera. 0 • all . te the operational elements mto t e organization's
that the orgaruzatton sh mtegra m~::::~~ :~~t~:sk Assessment,•: is yital ~nd ,lµghly signi~cant addition to the 2012 version 'of zio: It requires that: : · ·, ·
The organization shall establish and im~l~ment a risk assess,;,,ent process( es) appropriate to the nature of hazards and risks.
This provision recognizes the worldwide trend toward giving risk assessment a prominent place within safety and health management systems. Addendum A in Chapter 11, "A Primer on Hazard Analysis and Risk Assessment", provides a list of actions that have been taken in many countries to promote the inclusion of risk assessments as an integral. part o.f safety .endeayors ..
Brief comments, only, are made in this chapter on sections of 5.0 that are abundantly addressed in occupational safety literature. They are: "Contractors," 5.1.5; "Emergency Preparedness," 5.1.6; "Education, Training and Awareness," 5 .. 2; "Communication;' 5.3; and ''Document and Record Control Process;• 5.4. Comments are also made regarding 5 .1.3 .1, ''Applicable Life Cycle Phases," and 5 .1.3 .2, ~~Process Verification."
Separate chapters follow on the requirements in ZlO fQr which the literature is not quite as prevalent and which are vital in achieving superior results. Those-separate chapters are on:
• ~sk assessment, Sectio1,15 ,,1.1: Chapter 11 "A Primer on Hazard Analysis and Risk, Assessment" '' ·
• Risk assessment - 5 1 1 .... Ch · 1 " · . . · • Standard ' d . ·. · · apter 2 1~ · Provisions for Risk Assessments in s an Guidelines" . .
• Risk assess-ment - 5 1 1 ~h · · · · · · · k Scoring Systems" , · · - apter 13 - "Three and Four Dimensional Ris
• The hierarchy of control" s· .. · . . . , i,.,: . " • Safety design . s, ection 5.l.2: Chapter 14- "Hierarchy :of Controls
M ·, ., reviews, 5, l .3: Chapter 15 "S .c • • .,,
• anagenient of ch~ 5 - , . . . ::-- aiety Design reviews Pr · nge, .1.3: Chapter 19" "M, · ,, : · " • ocurement 5 1 4: Ch. · ·' · - , anagement of Change ' · · · apter 20 _ "Th · · · ·
Applied 1 e Procurement Process" . . ean concepts as dis . . , . provisions (Section 5.1.3) . Zclussed tn this book relate to the safety design·rr neW
tn O Chapt 18 ·. • · the · er · · , Concepts: EmphaslZlng
f INTRODUCTION 163
Design Process, contains a description of a system in which lean safety and environ- mental concerns were addressed in the design process.
contractors: Section 5.1.5 Relations with contractors who do work at an organization's site are addressed in this section. An organization is to have processes in place to protect the organization's employees from the risks that may be presented by the contractor's work or the activity of the contractor's employees, and to protect the contractor's employees from the organization's activities and operations.· These requirements are stated briefly.
A good reference on contractor selection procedures and the key safety, health, and environmental protection provisions to which contractors should adhere are discussed in the first chapter in Construction Safety Management and Safety Engineering. Also, entering "contractor safety requirements" into an Internet search engine will bring up a large number of downloadable examples of . procedures established by a variety of entities with respect to contractor selection and the safety perfonnance expected of contractors while on an organization's premises.
Appendix J pertains to "Contractor Safety and Health (Section 5.1.5)." It states: The purpose of this appendix is to provide organizations guidance with respect to exposures and control measures required to maintain the business by contracting for expertise and/or services. Examples are given of factors to be considered when contractors or service providers are engaged. Separate lists are included in the appendix of measures to be taken into consideration to control losses associated with on-site activities related to low-risk, medium-risk, and high-risk operations.
Six publications are listed as resources on contractor safety in Appendix 0, ''Bibliography and Reference". Two are standards approved by the American National Standards Institute (ANSI). One pertains to multiemployer projects; the other covers basic safety management elements in construction activities.
Two American Petroleum Institute (API) references give guidance.on implementing a contractor safety and health program. The International Association of Oil and Gas Pr<;xiucers (OGP) publication provides guidelines for wor~ng togeth~r iµ a coptract environment. An American Industrial Hygiene Association public~tion pertains to ~e health and safety requirements in contract documents.
Emergency Preparedness: Section 5.1.6 With respect to emergency preparedness, an ~rganization is t~ have ~r~cesses !n place to identify, prevent, prepare for, and/or respond to emergencies. This 1s_a subJ~t that has been much written about since the 9/11 catastrophe, the 2005 Katnna humcane, ~nd the 2012 Sandy hurricane. A good basic reference on· the subject c_~ be f~und ID Chapter 18 "Emergency Preparedness" in the National_ ~afety Counctl s Accident Prevention Manual: Administration & Programs, 13th edition. · •
Enter "emergency preparedness" into an Inte1,11et se~~h engine and th7 number of references available for review is well up _intQ the Illllhons. In Appendix O, five references for emergency preparedness are gjven: Federal Emergency Management
164 IMPLEMENTATION A ND OPERATION: SECTION 5.0 OF 210
. al p1·re Protection Association (NFPA) D MA) Nanon . , epart .... Agency (FE ' d two issued by the Occupatiohal Safety -411ent . (DOT), an and lJ Of
Transportatt~n A) They serve well as resources. qealth Administration (OSH ·
RAINING AWARENESS, AND COMPETENCE: SECTI EDUCATION, T ' . ON s.2 b. t an organization is to have processes in place t
For these four sdu ~fiec se, mployees and contractors,· see that they are eduo establish tency nee s or . catect compe that they understand, ensure that all involved are awar and · ed in a language e of a
tram . al health and safety management systems and their im Ppli. cable occupauon 'd . . Portanc
that the trainers are competent, and prov1 e trrumng. on an ongoing and ti' e, ensure . . 'd th · · h Id b · tnely b . 1 the advisory column, 1t 1s sat at trrunmg s ou e given, for exi:i- 1 as1s. n '41!,p e, to·
' '
a. Engineers in safety design ( e.g., hazard recognition, risk assessrn em, mitigation, etc.). : 1 •
b. Those conducting incident investigations. c. Those conducting audits. d Procurement personnel on the impact of purchasing decisions. e. Others involved with the identification of issues, methods of prioritization, and
controls.
An Internet search will reveal millions of resources on training and awareness ' but not as many on establishing competence levels. These chapters in the Accident
Prevention Manual are helpful:
• Motivation, C::hapter 28 • Safety and Health Training, Chapter 29 • Safety Awareness Programs, Chapter 31
Appendix O lists 'four publications pertaining to training, awareness, and compe- tence. Of particular interest is publication issued by the International Association of Oil _a~d Gas ~~ucers (OGP), Reference 6. 78/292. entitled "Competence Assessme~t {rammg Gut~elmes for th~ G~ophysical Industry." Despite the title, the docu~e~t is argely ge~en~ and the gu1delmes apply broadly to ·competence assessment trairung,
Enter .tbe_title mto a search engine and you will find that the document can be down- loaded without charge. ·
'
COMMUNICATION: SECTION 5_3 The standard's comm · • • • uon are in conned b' th· umcation provisions tequire that all levels of the organtza are
11 a out e OHSMS d th . . . . . d ·unesses reported promptly, em I an e _1mpl~mentat1on plan, i_~J~es an t on safetY and health P oyees be encouraged to -recommend rtnprovements. ....c:ted
matters, that th b . . . th r inte1vv ere e consultation with contractors and O e
111111----
REFERENCES 165
parties when changes are made that affect the occupational health and safety management system, ~d any b~ers to communication on hazards and risks and safety management deficiencies be elimmated.
DOCUMENT AND RECORD CONTROL PROCESS: SECTION 5.4
Toe organization is allowed some discretion with respect to its document and record control process. This is stated in the advisory column: The type and amount of formal documentation that is necessary to effectively manage an OHSMS should be com- mensurate with the size, complexity and risks of an organization.
Nevertheless, records shall be kept to demonstrate or assess performance with the requirements of this standard. In several provisions in ZlO, statements are made indicating that documentation is necessary (e.g., health and safety policy, objectives, implementation plan, audits, and management reviews). For many of ZlO's other provisions, activity cannot be managed properly without adequate documents.
REFERENCES
Accident Prevention Manual: Administration and Programs, 13th ed. Itasca, IL: National Safety Council, 2009.
Competence Assessment Training Guidelines for the Geophysical Industry. International Association of Oil and Gas Producers (OGP) Reference 6.78/292, 1999. Available at http:// info.ogp.org. uk/Geophysical/reports/M3. pdf.
Hill, Darryl C, Editor. Construction Safety Management and Engineering. Des Plaines, IL, American Society of Safety Engineers, 2004.
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