Oregon OSHA Online Course 100

Safety and Health Management Basics

MODULE ONE: MANAGEMENT COMMITMENT

Introduction

This first element in Oregon OSHA's safety management system model addresses management commitment. As you'll see below, commitment is more than just good talk. It's much more than that. To determine if adequate commitment exists, we actually have to evaluate the other six elements first. If management is doing a great job in each of the elements, I think we may assume management commitment is sufficient.

It is essential to the success of your company's safety and health program that top management demonstrate not only an interest, but a long term commitment to protect every employee from injury and illness on the job. But, if you think you don't have that commitment, how do you get it? It won't just appear out of thin air. What is the secret?

• The Legal Imperative. This describes the employer's legal duty to comply with occupational safety and health standards. When this is the primary motivation, safety is considered just another cost of doing business (CODB) that may drain the corporate budget. Unfortunately, the employer will do only what is required by law...probably not much more. The employer's primary goals are to:
  
  
  • Meet minimum OR-OSHA regulatory requirements
  • Avoid OR-OSHA inspections
  • Avoid litigation
  
  
  
• The Fiscal Imperative. The employer is obligated to corporate stockholders to operate the business in a financially prudent manner. In the private sector, this means "operating at a profit." In the public sector, this means "operating within budget."
  
  The goal here may reflect a reactive approach that emphasizes doing safety to reduce accident costs. However, if the employer really understands the long-term benefits of an effective safety culture, the goal will likely focus on proactively doing everything possible to maximize safe operations. (More on reactive and proactive approaches later in the module.) Safety is more likely to be thought of as "process-quality" and given priority equal to that of production. The employer's primary goals are to:
  
  
  • Meet or exceed stakeholder (stockholders, board of directors) expectations
  • Reduce workers compensation costs
  • Reduce indirect (uninsured) accident costs
  
  
  
• The Social Imperative. In the best-case situation, the employer feels a strong obligation to each employee, the community, and society in general to support and protect the welfare of all employees...its "corporate family." Safety is perceived as a core corporate value, not open to negotiation. The employer's primary goals are to:
  
  
  • Meet or exceed industry and community expectations
  • Protect corporate family members
  • Improve morale, reputation, and image

1. There is a written safety policy.
   
   
2. There are written safety goals and objectives.
   
   
3. Written strategies and tactics (plans) for achieving safety objectives are in place.
   
   
4. Managers provide safety budgets, staffing, and facilities for meetings.
   
   
5. Managers participate in executing safety plans.
   
   
6. Managers monitor and periodically evaluate the safety program.
   
   
7. Managers and supervisors set an example of good safety practices, e.g., wearing personal protective equipment.
   
   
8. Managers and supervisors are held accountable for safety performance, e.g., pay/promotions are partially dependent on safety.
   
   
9. Top managers receive and respond to safety committee recommendations.
   
   
10. Supervisors and managers personally conduct safety audits and inspections.
    
    
11. There are specific procedures for ensuring that accident investigations result in identification and timely implementation of corrective actions, and procedures are reviewed by management.
    
    
12. Managers attend safety meetings.
    
    
13. Management representatives are members of the safety committee.
    
    
14. Managers regularly attend safety activities outside the company.

It's up to you!

They say perception is reality and that's true for you because your reality resides inside your head. With that in mind, what can you, as a safety committee member, safety coordinator, or employee do about that reality? If management is not demonstrating commitment through action, then you have an opportunity to become a key player to get things moving.

With the help of the safety committee you can "educate up" to help management gain the vision and understanding needed to change their thinking. After all, thinking creates beliefs that drive attitudes and behaviors. So, your primary tool is education. Now let's take a look at what you can do to change that thinking.

Put safety into your mission

Your first step may be quite simple, yet it can have a major long-term impact on safety and health in the workplace. Make sure your company includes safety as a core corporate value in its mission statement. The mission statement tells the world who you are and what you do -- why your company exists.

If your company doesn't have a mission statement, develop a draft mission statement and submit it as a suggestion to help clarify purpose. Convince management of the benefits that will result from a written mission statement.

Sample Mission Statement

It is the mission of XYZ Widgets to safely manufacture and deliver the highest quality cyberwidgets to our customers throughout the Western United States. Now let's take a look at two different management approaches to safety and health that companies may adopt. Actually, most companies will adopt strategies that reflect an approach somewhere between these two "extremes."

Reactive vs. Proactive Safety Strategies

Don't just react to safety

It's sad but true - some companies may adopt an approach to safety and health that emphasizes a reactive strategy. A reactive approach assumes that accidents just happen, and there's not much that can be done about it. "It's not a problem 'til it's a problem."

The Reactive Process: Injury - Investigate - Recommend - Implement

The reactive safety improvement process begins when an accident occurs. By definition, reactive strategies look backward. Unfortunately, when an accident occurs it may be investigated primarily to determine if employees violated safety rules. Recommendations regarding possible discipline and correcting hazards are proposed. Finally, corrective actions and system improvements may be implemented.

As you can see, the company places most of its effort reacting to accidents after they occur. A reactive response occurs after an injury or illness and usually and its primary goal is to minimize accident costs. It’s a well-intended goal, but the strategy to achieve the goal is flawed.

The safety professional attempts to prevent future accidents by investigating previous accidents and other historical data. Reactive safety approaches usually cost much more than proactive programs because they are initiated only after an injury or illness occurs.

When management emphasizes a reactive approach to safety and health, it unintentionally communicates two negative messages to employees:

1. The leadership message that says, "we don't care about you,"
2. The management message that says, "it's all about money, not your safety."

• Accident investigation primarily to determine if safety rules were violated. Analysis is usually quite superficial and the search for root causes may not occur.



• Emphasis on an early return to work/light duty program. Great program, but it light duty should not be the primary tactical remedy in reducing costs.



• Incentive and recognition programs that reward employees for withholding injury reports. Promises of reward for working "injury free" may produce negative peer pressure and send a message that "every time there's an accident, it's the employee's fault." Actually, an employee can work all year in total compliance with all safety rules and still get hurt. On the other hand, an employee can violate company safety rules every day and not get hurt. The compliant employee would lose his or her reward while the consistent violator would receive a reward. Reactive incentive and recognition programs are very common. Chances are your incentive and recognition program may be reactive.



• Disciplinary program that is tied to accident record. You can bet adequate analysis has not been conducted if employees are being disciplined quickly after an accident.

Be smart...be proactive

A proactive strategy emphasizes anticipation. It means taking action to make sure accidents never happen in the workplace. There are no excuses for an accident. A proactive response to safety and health in the workplace occurs before an accident has occurred.

The Proactive Process: Identify - Anticipate - Analyze - Recommend - Implement

The proactive improvement process first identifies a hazard and anticipates the potential injury if the hazard is not corrected. Next, the hazard is analyzed to see if engineering and/or management controls might be used to eliminate or reduce exposure. The information gathered from the analysis is then used to produce recommendations. Finally, the recommended corrective actions and system improvements are implemented in the workplace.

The proactive improvement process predicts to prevent. Proactive strategies look forward. By emphasizing accident prevention, management sends a message of caring to all employees.

The safety professional attempts to identify and analyze hazardous conditions and unsafe behaviors in order to predict future accidents. Proactive strategies are always less expensive than reactive strategies. Remember, proactive programs are implemented to prevent future injuries and illnesses. Here are some characteristics of proactive safety and health programs:

• Accident analysis program to primarily determine system weaknesses. The employer conducts an analysis of the accident event to discover and improve safety management system weaknesses that may have contributed to the accident.



• Hazard identification and correction. Everyone is involved in identifying hazardous conditions by conducting periodic personal safety checks and inspections. Actions are initiated immediately to correct hazardous conditions.



• Behavioral analysis and correction. Employee behaviors are observed, analyzed and corrected. Focusing on employee behaviors may be quite effective in making dramatic improvements to workplace safety because most accidents, by far, are caused by unsafe or inappropriate behaviors.



• Employee wellness program. Employees are engaged in one or more programs that improve their physical and psychological wellness.



• Incentive and Recognition program. Employees are recognized for professional/safe behaviors that help prevent accidents in the workplace. Complying with safety rules, active participation on safety teams, and making suggestions are examples of proactive behaviors that are recognized.



• Safety committee/team. An active safety team that performs as an internal problem-solving consultant group.



• Education and training. All employees receive comprehensive safety education and training and are certified competent and qualified to perform hazardous tasks. Everyone is somehow involved in the safety education and training plan.



• Job Hazard Analysis (JHA). All hazardous tasks are analyzed to uncover hazards and develop preventive measures.



• Mandatory OR-OSHA safety programs. The company has designed and implemented written plans for the various rule-required safety programs (lockout/tagout, confined Space program, accountability system, etc.)

• Starts with an action verb. (Decrease, increase, improve, etc.)
  
• Specifies a single key result to be accomplished.
  
• Is quantifiable. Uses numbers to measure a desired change. (i.e., 50% increase)
  Specifies a target date for accomplishment.
  

• "Increase the number of safety observations by 25% by the end of this year."
  
• "Show a 35% reduction in back injuries by the end of 2007."

• worker's compensation claims
• uninsured recovery expenses
• civil liability damages
• litigation expenses

In addition, investing in safety keeps people safe and healthful, improves morale, productivity and the quality of service or product. Make sure your safety management system emphasizes accident prevention strategies rather than placing emphasis on strategies that merely minimize accident costs. The first strategy is proactive, while the second is reactive. We’ll discuss proactive and reactive approaches to safety later in this module.

Write a cost benefit analysis

If management is not displaying the desired level of commitment to safety and health, a solution to the problem may be to improve the quality of your written safety recommendations. One way to improve a recommendation is to include a cost-benefit analysis. The cost-benefit details the bottom-line advantages of investing in safety management system improvements. Let's review some of the information that you should be familiar with to write an effective recommendation.
Direct costs of accidents...only the tip of the iceberg

Direct costs for accidents are usually considered those insured costs covered by workers' compensation insurance and other minor medical expenses for the accident. The company pays insurance to cover these costs. The average direct costs depend on the nature of the injury or illness, but usually range from $1,000 to $20,000. A good round figure to use when estimating all average direct costs for lost time workplace injuries is $14,000.

Indirect costs: Hiding under the surface

Indirect costs are all the additional costs associated with an accident. It is important to realize that indirect costs are usually much greater than direct costs; from two to fifty times as costly. Another important point is that, unlike direct costs, indirect costs are uninsured: They represent an immediate debit in the corporate pocketbook. Indirect costs can drive your company into the red.

Consider what one lost workday injury might cost your company in terms of:

• Production downtime
• Productive time lost by an injured employee
• Productive time lost by employees and supervisors helping the accident victim
• Cleanup and startup of operations interrupted by an accident
• Time to hire or train a worker to replace the injured worker until they return to work
• Time and cost for repair or replacement of damaged equipment or materials
• Cost of continuing all or part of the employee's wages, plus compensation
• Reduced morale among your employees, and perhaps lower efficiency
• Cost of completing paperwork generated by the accident
• OSHA penalties

• The lower the direct cost, the higher the ratio between the direct and indirect costs. For instance, if someone suffers only minor injury requiring a few hundred dollars to close the claim, the indirect/direct costs ratio may be much higher than the NSC average. The following illustrate this variation:
  
  
• Capital intensive operations. Where large sums have been invested in facilities, employers may experience much higher average indirect/direct cost ratios. For example, if someone is seriously or fatally injured on a oil-drilling rig, resulting in operations shutting down for a day or so, many thousands of dollars in lost production will result. In high capital intensive work processes, the expected ratio between direct and indirect costs may be 5x to 50x or more.
  
  
• Labor intensive operations. Where more investment is put into labor than capital assets, employers may generally realize lower indirect/direct cost ratios. Someone may suffer a serious injury, but operations are not as likely to be significantly impacted. In labor intensive operations the expected ratio between direct and indirect costs may be 1x to 10x.

Next, divide that total by 5 years to determine an annual ROI of over 500 percent! Whoah! Now that's a return!

Management may want to know how quickly the investment will be paid back: what the Payback Period is. Just divide $28,000 by 60 months and you come up with $467 per month in potential accident costs. Since the investment is $1,000, it will be paid back in a little over two months. After that, the corrective action is actually saving the company some big money. Now that's talking the bottom line!

When recommendations are not acted upon it is usually because management does not have enough useful information to make a judgment and therefore does not act right away. To speed up the process and to improve the approval rate, you must learn to anticipate the questions that management may ask in order to sign off on the requested change. The more pertinent the information in the recommendation, the greater the odds for approval. What are the key elements to improve your odds?

Here's an example of an excellent recommendation submitted by a course graduate, Dianna G

1) Problem: The guard rail in the warehouse has deteriorated to a point that it is unable to support any weight on it.

2) History: We had an incident on 6/13/99 where Joe Blow almost fell down the 10 steps because the guard rail did not support his weight. He fortunately caught himself before falling. We had a second near miss incident on 9/18/99 when Jane Doe tripped going up the stairs and grabbed for the rail which did not support her. Again, fortunately she caught herself before falling.

3) Options to correct problem: We have attempted to tighten and brace the rail but it continues to work itself loose. We took bids to replace the rail and the bids ranged from a high of $3,200 to a low bid of $1,500. We believe the XYZ brand for $2,000 will prove to be the best material for our facility. The disadvantage to the lowest bid of $1,500 was it would not be guaranteed for outside weather conditions.

4) We budgeted "x" for off-site training classes and have secured a source for on-line no-cost training through OSHA which could save "X" dollar that could be applied toward part of the cost of the guard rail.

5) Cost/Benefit:

ROI. Average cost of a severe injury in Oregon is $9,700 which is very possible if one of our employees should fall from the second story of the warehouse to the concrete pad below. The estimated indirect cost is $17,500. Total accident cost is estimated to be $27,200. ROI will be approximately 1,360 percent!

Payback Period. I estimate that the probability of an accident occurring within the next two years as a result of this hazard is very high. Therefore, the payback period is based on 24 months. Our cost for corrective action is $2,000 and the pay back period would, therefore, be less than 2 months ($1,133/month.) .

Take Action

Now you have some ammunition to help get top management commitment you'll receive many more tips and ideas about this throughout the course. Right now, let's take a look at developing an effective action plan to get top management commitment. An action plan is nothing more than a set of long-term strategies and short-term tactics ("how" statements).

A Sample Action Plan

First, examine the quality of the information your safety committee is giving management. The more useful the information you provide, the more likely management will take positive action on your committee's recommendations.

Are you talking the "bottom line" with management? Is the safety committee able to present management with the estimated costs for correcting hazards? Can they estimate the much higher costs associated with accidents that might happen if the hazards are not corrected?

Are all members of the safety committee trained on their duties and responsibilities, hazard identification and control principle, and effective accident procedures?

Second, evaluate your company's accountability system that clearly informs, and includes procedures to consistently and fairly enforce safety rules. A written recognition/disciplinary plan should apply equally to all employees.

Are you and the safety committee emphasizing that responsibility needs to be assigned to line managers, from the top on down to the lead person for carrying out safety and health programs. Management carries out the program by conducting safety training, providing close supervision, and by enforcing safety rules consistently. This responsibility should not be delegated to staff people such as the safety director or safety committee, who usually have neither the responsibility nor the authority to take action on those programs. To be most effective, safety supervision, training and enforcement should be line management's responsibility.

Are supervisors adequately trained in identifying hazards and safety procedures associated with the tasks that their workers perform?

Third, establish a program that awards appropriate safety behavior. Appropriate behavior includes:

• complying with safety rules,
• reporting workplace hazards, and
• and injuries.

Let's Review!

1. "Just tell me what I have to do to comply" best reflects which safety imperative:

a. Fiscal imperative
b. Legal imperative
c. Moral imperative
d. Ostrich imperative

a. Complaining about the lack of commitment
b. Threatening to complain to OSHA
c. Providing useful information
d. Inviting management to committee meetings

a. Your Workers' Compensation insurer
b. Your friendly OSHA consultant
c. A private consultant
d. Any of the above

a. True
b. False

a. costs
b. losses
c. investments
d. outlays