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?
