Risk Based v Compliance Based - Are They Mutually Exclusive

Risk based versus compliance based are they mutually exclusive?

Let me preface my question with this; I have always held to the belief that if an organization wants to have a world class safety culture it starts with abandoning the stance that compliance with OSHA is the main goal. That said how do we, as safety professionals, communicate to our leadership the difference between risk based and risk taking? This becomes more difficult when we are addressing low probability high consequence events.

Those that are familiar with the risk process know that there are basically four risk treatment strategies: avoid the risk, reduce the risk, transfer the risk, and accept the risk. The key to successfully applying one of these strategies starts with identifying what risks are present. This is also where, in my opinion, many organizations struggle. Risk perception goes hand in hand with our experiences and changing those perceptions can be challenging. The best examples regarding risk perception that I can point to is elevated work. We work at heights both on and off the job countless times without incident therefore to many this can be perceived as a low risk activity and the strategy chosen is accepting the risk. Unfortunately, this perception is untrue and has led to too many serious injuries or deaths. So then why does fall protection consistently year after year land in OSHA's Top 10 listed? In the December 2016 issue of Safety + Health, published by the National Safety Council they list OSHA's Top 10most cited violations for fiscal year (FY) 2016 out of the top 10 cited, elevated work was captured 3 times (#1- Fall Protection General Requirements, #3- Scaffolding, and #7 - Ladders). What is alarming is that when the top 10 "serious" and "willful" violations for FY16 were parsed, again elevated work was prominent holding 4 of the top 10 spots in the "serious" category (#1- Fall Protection, #3- Scaffolding, #6- Ladders, and #10 - Fall Protection Training) and 2 positions in "willful" (#1- Fall Protection and #6- Scaffolding).

Although I can recite chapter and verse of many OSHA standards, I have always reverted back to the preamble of the standard to understand the intent of why a particular rule was promulgated. One thing that I am convinced is that there are no proactive OSHA standards and that rules have been promulgated as a result of pain, suffering, and hardship to many not just a few. Understanding the intent of the standard helps me gain clarity on the real risk involved and this clarity along with my experiences then forms the basis of my risk assessment. From an informed position I can suggest risk treatment strategies. Using elevated work again as an example the intent of the standard is to ensure that employees are not seriously injured or killed as a fall when working at heights. The standard allows the employer to apply fall protection or fall prevention techniques to reduce this risk. Working within the content of the various OSHA standards covering aspects of elevated work there are many viable options that can be employed that can address the risk.

So back to the question risk based versus compliance based are they mutually exclusive? What are your thoughts?

Employee Engagement Starts By Looking In The Mirror

For a safety culture to thrive and be sustainable employee engagement is a must. So how do we, as an organization, foster employee engagement? Employee engagement starts with trust.  The first step is to take a hard look into a mirror. Does the reflection show a leadership team that has the trust of the workforce or is there an us and them mentality? Knowing the level of trust will be able to shed light on the next step required to improve or sustain the culture.

If your organization's paradigm is such that the level of trust is low then leadership's next move is to improve in that attribute. Start by understanding why the employees hold this belief. In Stephen R. Covey's highly acclaimed book The 7 Habits of Highly Effective People habit number 5 is "seek first to understand, then to be understood" because without this base neither a person or an organization can expect to improve. Only when we understand what those challenges and barriers in our way are can develop an action plan to mitigate those obstacles. This holds true whether you are trying to improve or sustain your organization's culture.

Sustaining a strong safety culture is a challenge in of itself. Too often leadership feels once they reached a level of success and that perpetual motion will take over making their strong culture self-sustaining. History has shown that, that is not reality. What is real is that every organization is dynamic in nature. Therefore, you must continually build and maintain trust throughout the workforce, seek to understand the true status of the organization's culture, stay ahead of the inevitable decline phase by re-invigorating programs, and continue to take that hard look in the mirror.

"Coming together is a beginning; keeping together is progress; working together is success."
Henry Ford

OSHA Regulations Are Minimum Standards Not Gold Standards

Too many organizations fool themselves and think complying with the OSHA requirements actually means that they have a good safety program and culture. The truth is, that they are actually poised to fail. Remember that these requirements are minimum standards so by adhering to them you have left little room for error. The best example I can provide to illustrate the potential for failure is employee exposure scenarios. OSHA publishes many exposure levels most are equated with a permissible exposure limit (PEL) 8-hour time weight average. You should remember that PELs are not absolutes but what most people can be exposed to without adverse health effects. So for some workers, adverse health effects may occur. Additionally, many of the PELs are outdated. This being said, I’m not advocating becoming risk adverse.

We are exposed to risk in almost everything we do. For an organization to have a progressive safety culture they need to evaluate those risk and where possible eliminate what you can. Where you are unable to eliminate the hazards then a mitigation strategy must be applied. This strategy should follow the hierarchy of controls employing engineering controls first followed by administrative controls and work practices the lastly the use of Personnel Protective Equipment (PPE).  The key is to evaluate your work processes and seek out activities where following the minimum requirements could have adverse effects if sliding off that minimum edge occurs.

“Don't lower your expectations to meet your performance. Raise your level of performance to meet your expectations.”  Ralph Marston

Are You A Safety Manager Or Safety Leader?

Many of us have the title of “Safety Manager” yet in today’s business culture the typical managers are inefficient. Organizationally what is needed, is to evolve to “Safety Leaders”. There is an axiom that states “you manage things but you lead people”.  Leading people is paramount if you are to be successful in the safety field.

During my long career I have always tried to conduct myself as a leader and not a manager. This is not to suggest that I don’t focus anytime on managerial tasks (like program management elements) but for me coaching and leadership activities is where my heart goes. This means being in the field and talking with as many people as I can. For me it is about asking if they have any concerns, are there any barriers to performing work safely, or sometimes just talking about what they did for the fun. I came up through the trades so walking among craft personnel is natural for me. Having a common background also gives me an advantage in building trust. For a leader trust is the cornerstone of a strong foundation. Trust is not given easily, especially in construction work where the work is transient. Therefore, you need to constantly work at it. We have all heard the phrase one “aw crap” will erase a trunk full of “atta boys” so remember trust can be fragile; protect it.

If trust is the cornerstone, then integrity is the mortar that holds the foundation together. Without integrity trust will erode quickly and the foundation of your program will crumble. Integrity is about doing what you say and saying what you do. It is a simple process but too many have failed to grasp it.  Integrity combined with trust is what Safety Leaders leverage to propel an organization’s safety culture in a positive direction. When you try to “manage” versus “Lead” you naturally gravitate towards an authoritative stance where you end up being a “safety cop”.

So do you still want to be a “Safety Manager”?

 I’ll choose being a “Safety Leader” because as Tom Peters so eloquently put it “Leaders don’t create followers; they create more leaders”.

If You Want To Succeed, There Better Be An "I" in Team

If You Want To Succeed There Better Be An "I" in Team!

We have all heard (and probably uttered) that there is no "I" in TEAM but to be successful this can't be further from the truth. The definition of team is a collection of individuals working toward a single objective. In order to meet the objective every member of the team must be accountable for doing their part. If any member of your team does not accept accountability for their role as a member of the team meeting your objectives will be challenging. To ensure that team members become accountable they will each need to understand what is expected of them and where their role fits in to the overall scheme. Leaders will need to clearly state expectations and discuss these with each of the team member so that the team has a clear understanding of the path required to meet the objective.

So how do I apply this to safety management? From experience I can tell you that when safety is the just the responsibility of the safety staff your organization will struggle and the only time “accountability” is discussed is during an incident investigation. If you are the safety guru then you need to have a dialogue with your management team and start instilling a sense of “accountability” across the whole enterprise. This starts with communicating clear expectations up, down and across the organization. In order to be a driving force towards improvement these expectations need to be discussed, shared, and finally accepted at all levels. Therefore, they cannot be an edict sent down from above or it will be just an another flavor of the month and will evidently lose traction and then sputter to just a memory. This is a process and not just a onetime event. Like anything worthwhile it takes full commitment and engagement from every level. You will undoubtedly come up against team members that are reluctant and resistant to putting in the effort and here is where leadership qualities will need to surface. It is the leader's task to work with those that fail to grasp or understand how accountability provides a benefit to not only the organization as whole but to the individual. To get people to become engaged you must win their confidence.

Accountability should not invoke a negative emotion.  Accountability will instill a sense of pride and accomplishment. When we hold every one accountable to their expectations we propel the entire organization upward and together we all can achieve more. I leave you with this short quote from Coach John Wooden “The main ingredient of stardom is the rest of the team”

Lessons From Failure

Lessons From Failure

For an organization to thrive and mature it must learn from its mistakes. This is also the main purpose of performing root cause analysis. Earlier in the week I saw a post where the author asked the question, why does management ask to review the JSA after an incident occurs? My initial thought was to learn where the system broke down. As I read the comments I started to realize that for many the answers were akin to how to fix blame to what happened. In my experience unless there was blatant and willful misconduct blame needs to be removed from our thought pattern. What we need to do is to look hard at the event to determine what part of the management system broke down that allowed the incident to occur. We can then apply what we learned so that, organizationally, we reduce the potential of repeating our flawed history.

One of the common root causes that I have witnessed is Management Oversight Less Than Adequate (or some variation). This can be viewed in one of two ways first is to blame the Supervisor for doing a poor job watching the workers but if you look back to my earlier statement on blame I doubt it is very likely that blame is the culprit. Since blame is now out of the equation the second option, becomes more prominent, what barriers were present that reduced the effectiveness of the management oversight? This is where the real value of your investigation lies and where you can create the learning/teaching moment. By peeling back, the layers of the onion you reveal what were the barriers to effectively managing the workforce. Is there a lack of resources, are the supervisors spread too thin, is work being properly authorized, are workers encourage to work independently, the barriers can go on and on.... Knowing what failed permits an organization the opportunity to strengthen those particular weaknesses and then develop a corrective action plan that can be monitored and later assessed for effectiveness.

We all are prone to errors and failure what we do with the lessons that come out of those failures determines whether we grow  organizationally or as George Santayana stated "Those who cannot remember the past are condemned to repeat it." 

Welcome to Insights In Safety

In 1990 I decided to change direction and become serious about working in the safety and health field. I have worked under all 3 OSHA standards General Industry, Construction, and Maritime but this blog will not be about OSHA requirements but safety management practices that are universal regardless of your industry. After 25 plus years I have learned and experienced a lot so now is the time to share those lessons learned. Over the coming months my goal is to capture these experiences in this blog as a tool that will be useful to others. I encourage the reader to be interactive and together we can grow.

My vision is for this blog to useful to safety professionals and those assigned to be your organization's safety guru. So if you are ready let us start journey together. 

Paul A. Collins CSP, OHST