Cority’s Sean Baldry, CRSP, recently hosted a webinar on OSHA’s Top 10 Violations of 2019 where he explored why companies still struggle to address the same workplace risks year after year. Sean provides answers below to some of the great questions from audience members we didn’t get a chance to cover during the webinar. Read on to learn more about how to get management involved in your safety program, training tips, and where to focus your efforts to drive safety performance.
In your opinion is OSHA doing enough to improve workplace safety? I know plenty of employers that have never had an OSHA inspection conducted. The lack of inspections may inadvertently allow employers to remain non-compliant knowing that OSHA is stretched very thin.
We could always debate the extent to which government plays a role in protecting the health and safety of workers. Yet on whatever side of the fence you sit with respect to this question, we need to acknowledge that it’s more a question of practicality. While OSHA inspections can be effective at compelling employers to meet the minimum standards set by law, this process is extremely inefficient considering the number of inspectors available and the number of workplaces (and workers) across the country.
It’s important to realize that no group is better equipped to identify and control workplace hazards than the people that occupy that workplace every single day. To maintain adequate levels of workplace safety sustainably over time, employers and employees must work together to build a health and safety program that clearly acknowledges rights and responsibilities, and that establishes basic elements that are necessary to effectively manage risk: hazard identification, training and education, proactive inspections, and preventive maintenance to name a few. OSHA inspections should serve as simply a “check” on that process, ensuring it is working smoothly, and highlighting areas where further attention is needed.
I would argue, however, that employers need to take the first step and set the conditions to allow such a workplace culture to grow. They must set the tone that health and safety is a fundamental right of every individual, that they are committed to building a strong safety culture, and that workers will have an opportunity to actively participate in that process.
How do I get the owners of the company involved in our safety program?
An error committed by most EHS professionals is that they believe they themselves are the “owners” of the health and safety program. That could not be further from the truth. Health and safety practitioners are advocates and advisors for health & safety. And while they are not inherently responsible for the health and safety program and its outputs, they are responsible to ensure that workplace parties, employers and employees alike, have a firm understanding of their rights and responsibilities for safety, and what they need to do to help protect people from harm.
Consequently, while health and safety professionals cannot compel leaders to “get involved” in the safety program, they need to help identify and communicate to leaders the reasons why their involvement is critical to the overall success of the business. And while there is no foolproof way of achieving this, I would recommend two approaches to get started:
1. Get the leaders to understand the value of health & safety from a business perspective
Let’s be honest: not every person subscribes to an ethical argument for safety. That said if safety is positioned as a factor that could either help or hinder the organization achieve its business and/or financial goals, that could help sway leaders to recognize the value that safety can bring to the company.
It’s been clearly established in research that organizations with strong safety performance tend to have equally strong overall business performance since many of the processes to achieve safety results support greater business outcomes – strong communication, planning, assessing risk and potential for failure, and building controls into processes to respond to variability. But this all starts by recognizing what’s most important to your leaders and positioning safety as a tool to help them achieve those goals. And advocating for their involvement in safety in a language they understand is a great first step. For helpful tips to effectively speak the business language of the C-suite, be sure to check out our eBook, Mastering the Art of Communication for EHS Professionals.
2. If you want to get leaders more involved in safety, then get them involved.
This means having owners and executives take an active role in participating in the key processes within your safety program. Having owners participate in workplace inspections will give them a better understanding of the environments in which their employees work, the condition of equipment and the possible need for investment, and may even expose them to how decisions made at the top can directly impact how employees work and their overall risk of injury.
Similarly, getting leaders to actively participate in regular safety meetings not only affords them the opportunity to reinforce to their workforce their commitment to safety but gives them an unfiltered perspective on current issues and morale that can have impacts far beyond health and safety. Spending “time in the field” gets leaders to appreciate the impact that injuries can have on workers and hopefully helps them to recognize the moral arguments for safety, in addition to the legal and financial ones.
You may need to be quite deliberate to start – schedule a specific date/time to have leaders join you and other workers in the field for meetings or inspections. Once the initial hesitation is gone, they will be more likely to repeat the behavior moving forward.
What is your suggestion for training workers across multiple shifts?
Training workers across multiple shifts is a common challenge for many organizations, especially where the individuals who normally organize and/or deliver safety training work on a single (day) shift. As a result, organizations need to be clever in planning how to complete training for employees that may work on afternoon and night shifts, when supervision may be lower and administrative support is not normally available.
During our recent webinar, we discussed the need for employers to consider different approaches to safety training delivery, considering workforce demographic shifts, current operating constraints, and changes in the manner in which people learn in a “connected” world. Yet during this discussion, we acknowledged that building a sustainable training program starts with completing a training needs analysis.
The training needs analysis will allow you to determine what hazards are present in the work performed, which employees are exposed to those hazards, and what skills and/or competencies workers require to best control these hazards and complete their work safely. Any plan to train workers across multiple shifts should start with this approach.
The training needs analysis will also help you to determine what specific skills your employees require, and what approaches are best suited to provide those skills. While considerable debate exists, training via e-learning platforms or microlearning apps is generally suitable to build awareness of key ideas, topics or policies, or to reinforce learning that had been acquired previously. In contrast, if workers need to develop practical “hands-on” skills, facilitated training may be most appropriate, and may require scheduling trainers to meet workers during these “off” shifts.
One cautionary note: the principle of “on-demand” training applies in all cases. Whenever planning employee training, consider the time lag between when a new skill is learned and when it can be practiced or applied. The more time that passes between when a skill was first learned and when it can be practiced will prevent skill “hardening” and make it more difficult for the worker to repeat the desired behavior. This is particularly important when training workers across shifts. It means that you may need to rely on supervisors to follow-up and provide tasks to workers on the afternoon and night shift to allow them to practice new skills frequently so they become repeatable.
If all else fails, seek out assistance from a training consultant who may be able to assist you with training approaches that meet your unique needs.
What are the top 3 initiatives employers should focus on to drive safety performance?
It’s difficult to answer this question objectively, considering the number of different opinions and sources on the subject. I would argue, however, that there are a few items that all leaders need to consider if they desire to build a strong safety culture within their organization:
1. Communicate – Culture can be defined as a shared set of values, opinions, and beliefs. Safety culture is often described as the shared values, opinions and beliefs in how safety is (or should be) prioritized against other conflicting priorities. The point here is that developing a set of shared values, opinions and beliefs starts with creating a process of open and transparent communication across the organization. When organizations create an environment where all employees feel free to speak openly about concerns, ideas, and suggestions, it helps to create these common perspectives and beliefs on the importance of safety that is necessary to building a strong culture.
2. Lead by Example – Workers assess the organization’s commitment to safety not solely on what leaders say, but more on what they do. This is why it is critical that leaders actively demonstrate behaviors that are consistent with their shared values and beliefs. If we say personal protective equipment is important, then it is crucial that workers see their leaders wearing the same gear they are expected to wear. Workers will not buy-in to safety if policies and procedures are not being followed by their leaders. Safety means walking the walk, not simply talking the talk.
3. Involve Workers – Building a safety culture starts by building it from the ground up. Securing employee commitment and buy-in requires getting workers actively involved in the safety program, not simply being passive recipients of its outputs. Seek opinions from workers on how to make processes more efficient and safer. Actively involve workers in change management initiatives. Give workers opportunities to lead safety discussions, and give them autonomy to deal with safety issues, at least minor ones, without first asking for permission. These simple actions will pay huge dividends when building a sustainable safety culture.
For Fall Protection, how long (time frame) are harnesses valid for? Do they expire?
Most regulatory authorities and standard-setting bodies (i.e. ANSI) have held that it’s up to the manufacturer of personal fall protection equipment to set the maximum shelf life of their products. This would include full-body harnesses and any connecting devices (i.e. lanyards). Some manufacturers have set this limit at 5 years from the date in which the device was placed into service, but others will argue that the useful life of a harness can be extended if the equipment is effectively inspected and maintained.
It’s important to remember, however, that the manufacturer’s recommended shelf life is based on use of the fall protective device in ideal conditions. Fall protection soft goods can degrade over time when exposed to extreme temperatures, direct sunlight, or petroleum-based products, including cleaning agents. Whenever using fall protection equipment, it’s most critical that workers inspect the equipment before donning it. These proactive inspections are the first step toward identifying equipment issues, which if left unchecked, could lead to a catastrophic failure.
While digitized safety and training measures are becoming the norm, how important do you think visual cues like safety signs and boundary markers are in the workplace?
While safety signs and boundary markers can provide effective visual cues to alert workers to a potential hazard, we need to acknowledge the relative effectiveness of these measures with respect to the Hierarchy of Controls (HOC).
The principle of the Hierarchy of Controls holds that higher-order controls are most effective at controlling exposure to hazards since they do not involve any conscious decision-making by the worker involved. In this respect, higher-order controls, including elimination or engineering controls, protect the worker from the hazard by either removing the hazard altogether or placing a barrier between the hazard and the worker. Lower-order controls, including administrative measures like procedures, and Personal Protective Equipment, are less effective since they require a decision from the worker to apply and/or follow these measures.
To that end, safety signs and boundary markers are administrative controls, in that they will alert the worker to potential danger, but still require a decision from the worker to recognize, acknowledge and respond appropriately to that cue. If a boundary marker identifies a potential danger, but the worker fails to acknowledge it or bypasses the boundary anyway, then we can consider the control to be less effective.
This is not to say that safety signs do not have a place in the collection of control measures that we can deploy to appropriately advise and protect workers from danger. We must realize, however, that the protective quality of control measures are themselves not equal. A thorough risk assessment of your workplace is a good place to start to identify hazards, the risk these hazards pose, and what control measures are most appropriate in the circumstances to reduce risk to a tolerable level.
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