Category: Safety Management Series

As detailed in the Section 5 (The General Duty Clause) of the OSHA Act, the employer is assigned responsibility and held accountable to maintain a safe and healthful workplace. The following is an excerpt from Public Law 91-596, 91st Congress, S. 2193, December 29, 1970.

Section 5

(a) Each Employer –

• (1) shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees;

• (2) shall comply with occupational safety and health standards promulgated under this act.

Employers can be cited by OSHA for violation of the General Duty Clause if a recognized serious hazard exists in their workplace and the employer does not take reasonable steps to prevent or abate the hazard. The General Duty Clause is used only where there is no standard that applies to the particular hazard.

 

OSHA-Mandated Responsibilities

As you can see, employers have clearly defined responsibilities under OSHA, and as the “agent of the employer” the supervisors have the same responsibilities for the employees they supervise. The following list are basic responsibilities stated throughout OSHA standards.

• Provide employees a workplace free from recognized hazards. It is illegal to retaliate against an employee for using any of their rights under the law, including raising a health and safety concern with you or with OSHA, or reporting a work-related injury or illness.
• Comply with all applicable OSHA standards.
• Report to OSHA all work-related fatalities within 8 hours, and all inpatient hospitalizations, amputations and losses of an eye within 24 hours.
• Provide required training to all workers in a language and vocabulary they can understand.
• Prominently display this poster in the workplace.
• Post OSHA citations at or near the place of the alleged violations.

Identifying Hazards

The employer is responsible for identifying hazards. It’s useful to categorize them into four categories:

• The first three categories (materials, equipment, and the environment) represent hazardous conditions. Hazardous conditions are the surface causes directly account for only a small percentage of all workplace accidents.
• The fourth category (people) describes employee behaviors. Employee behaviors represent the surface causes that contribute to or cause a higher percentage of workplace accidents.

 They are the root causes that ultimately contribute to or cause most accidents.

Check Out: Guide to OSHA Requirements for Small Businesses

Let’s review these four categories:

Materials: liquids, solids and gases that can be hazardous to employees.

• Liquid and solid chemicals (such as acids, bases, solvents, explosives, etc.) can produce harmful effects.
• Raw materials (solids like metal, wood, and plastic) used to manufacture products are usually bought in large quantities and can cause injuries or fatalities in many ways.
• Gases, like hydrogen sulfide and methane, may be extremely hazardous if leaked into the atmosphere.

Equipment: machinery and tools used to produce or process goods.

• Hazardous equipment that is improperly guarded and places workers in a danger zone around moving parts could cause injury or death.
• Lack-of a preventive and corrective maintenance will make it difficult to ensure equipment operates properly.
• Tools that are not in good working order, improperly repaired, or not used for their intended purpose is only an accident waiting to happen.

Environment: general area that employees are working in.

• Poor facility design, hazardous atmospheres, temperature and/or noise can cause stress.
• If areas in your workplace are too hot, cold, dusty, dirty, messy or wet, then measures should be taken to minimize the adverse conditions.
• Extreme noise that can damage hearing should not be present.
• Workstations may be designed improperly, contributing to an unsafe environment.

People: employees, managers, supervisors, in the workplace.

• Unsafe employee behaviors include taking short cuts or not using personal protective equipment.
• Employees who are working while fatigued, under of influences of drugs or alcohol, distracted for any reason, or in a hurry are “walking and working hazards.”

There is one sub-catergory that is often able to be added, especially when building up a safety culture, and that is:

Supervision: this is managers, supervisors, directors, top down issues.

• Management may unintentionally promote unsafe behaviors. For example, they may ignore unsafe work practices.
• Inadequate or missing safety plans, programs, policies, processes, procedures, practices, and rules (written and unwritten) may somehow result in injury, illness, or death in the workplace.
• Not training employees how to work safely
• Not supplying employees with the right tools for the right job.

Want to learn more about Root Cause Identification?

Surface Cause Analysis – Why did the accident occur? Here you determine the unique hazardous conditions and unsafe behaviors that interacted to produce the accident. Each of the hazardous conditions and unsafe behaviors uncovered are the surface causes for the accident. They give clues that point to possible root causes/system weaknesses. Examples of surface causes include:

• A broken ladder
• A worker removes a machine guard
• A supervisor fails to conduct a safety inspection
• A defective tool

Root cause analysis – Why did the surface causes occur? At this level, you’re analyzing the weaknesses in the safety management system that contributed to the accident. These weaknesses are inadequate/missing safety components such as policies, programs, plans, processes, procedures, or practices. Examples of root causes include:

• Inadequate or missing safety management system components.
• Inadequate performance or failure to carry out system components such as: failure to train, failure to provide PPE, and inadequate implementation of safe procedures.
• Failure to enforce safety rules, discipline for safety infractions or recognize safe performance.
• Failure to conduct safety inspections, JHAs, and incident/accident investigations

According to the Broken Windows Theory of Crime, if a broken window is left unrepaired, people walking past it will assume no-one is in charge. Within a short space of time, more windows will be broken creating a subtle indication that anything goes.

Crime is contagious and works like an epidemic.

So, if a broken window attracts more crime, does this mean that a workplace that is poorly cared for has more injuries?

And the answer is simple: yes.

According to a study by Dave DeJoy and Todd Smith from the University of Georgia’s College of Public Health, they found a well-kept site means safety is a priority.

Crime is contagious. So is not caring about where you work and the safety of your workmates. Organizations that allow untidiness and broken equipment are subconsciously saying that safety and equipment aren’t important. By fixing up the little things in your environment (e.g.: broken/unsafe machinery, PPE that needs replacing), you fix up the safety culture.

High performance companies keep their workplace cultures in check by balancing core areas. These are Unity, Compassionate Leadership and Communication. Together, these factors hit the sweet spot for trust (which is when people feel safe). Trust is integral for a high functioning culture.

As Simon Sinek says in “Start with a Why”, “only when individuals can trust the culture of an organization, will they take personal risks to advance the company. Great organizations become great because the people inside feel protected”.

This desire “to feel safe” is two-fold, it means feeling safe to excel and take risks in your career, but also knowing that you are protected from getting injured at work or from being bullied or harassed by colleagues.

3 Simple Steps to improve safety culture

To get to “Trust”, companies need to align themselves with the following three inter-related factors that are driven from the top, but are orchestrated at every level:

1.Unity– High performing workplaces are unified and have every-one working together as a team. There is no “Us versus Them” mentality.

Humans have a very strong and instinctive desire to be part of something bigger than themselves. It’s the same at a workplace. Staff want to be part of a group and a successful one that’s going somewhere. It’s important for companies to cultivate a strong sense of group identity. This means that all communication uses the terms “we” and us” and that clear goals are set.

Check Out: Be Aware of the Negative Aspects of Positive Reinforcement

2.Compassionate Leadership– We all need to feel loved and appreciated. It’s important that companies convey this to their staff. Not just through words, but through the right actions.

Staff and even visitors, to your workplace, will look for visible signs that staff are highly valued to the organization.

This means looking for evidence of:

• A tidy, clean kitchen and toilet area,
• Clean workspaces,
• Operational equipment,
• Clean PPE, and
• Happy staff working together.

By ensuring a tidy work environment and operational equipment, leaders ensure that subtle messages are given that only productive and safe behaviors are tolerated.

Other more intrinsic signs are that staff ‘s personal needs are considered important and that they are listened to, if they have any concerns.

Check Out: Successfully Persuade People That Workplace Injuries Are Preventable

3.Communication– Finally, we have the final step that communicates the other two areas but in a transparent, predictable manner. This is where communication connects staff emotionally to the information by using stories and metaphors.

Communication must be regular and transparent. Woe betide any CEO who dares to announce that safety is important, but in a later announcement declares that due to poor sales, the safety budget is going to be cut. Messages must always be transparent and credible.

They must also include:

Unity messages that working at the company is a team effort, that group goals are achievable and that looking out for teammates is required, while being responsible for your own safety.

Compassionate messages that the company wants the best for staff, that staff contributions are welcomed, and that safety is a priority.

Communication is also open at all levels and staff can offer feedback that is actioned rather than ignored.

By ensuring that these three factors are in balance, organizations ensure that their workplace is highly functional and cohesive, with trust being the centerpiece of how the organizations operates.

There are a number of reasons why so many safety courses fail to provide results in the workplace.

 Ten of the most common reasons for the lack of results in safety training

• The most important one is that the environment to which the participants return is not blessed with effective leadership. This ineffective leadership does not encourage or foster a safe environment. Often, there is a culture of blame when there is an accident or incident.

Check Out: How Effective Leaders Use Positive Reinforcement For the Greatest Effect

• Next, the training is purely knowledge-based and not behavioral based. This means that whilst the participants may leave the course with extra knowledge, they don’t necessarily know how to apply it. Academic teaching methods are used, theories are expounded and there are few practical elements in the training. Safety is an emotional subject and the training programs must be designed with care.
• Safety Training can be boring in the wrong training hands. This is a great turn off for so many people attending the courses because they become disengaged and will not accept any new concepts or change their behavior back in the workplace.
• Frequently, the person taking the training course does not understand how people learn. This means that most of the money, effort and time is wasted and the participants become cynical and unwilling to embrace new ideas.
• Because so many training courses attempt too much, the group members rapidly go into an overload coma. When this occurs, no learning takes place and consequently no behavioral change back in the workplace.
• The participants are subjected to endless videos and “death by PowerPoint™” This means that at least two thirds of the group members are not reached by the information.
• The training is not fun. Worldwide research shows that training which is fun with plenty of humor is much more effective in terms of the retention and attention of participants. Furthermore, there is a greater acceptance of new ideas and concepts.
• The managers are not trained with the rest of the staff. This means that there is always the opportunity for a greater disconnect between the two groups in terms of common goals and objectives.
• There are no training objectives which are shared with the participants. They are not included in the process of setting goals and objectives nor are the involved in deciding how these are to be reached. There are no expectations set for performance after the training.
• There is no follow-up coaching on the job so that training is taken out of context and is irrelevant. There is no measurement of changed behavior.

If the participants in the training are not asked for a commitment to a safer working environment, it is unlikely that they will spontaneously give it.

Trust forms the foundation for effective communication, employee retention, staff motivation and contribution to discretionary effort and most importantly workplace safety. So how do you maintain and build on the trust you may currently have in your workplace? This is an important question for today’s world of change. We know from our experience that when there is trust within any group, team organization, any change is easy to establish and maintain. It seems that trust underpins almost everything that we try and do in today’s organization.

We all think we understand about trust because of our own experiences. But it seems to stop there. How do we improve trust levels between people? One of the reasons that this is such a difficult question is that we have always considered trust as a quality by itself. It has been suggested that we should consider it differently. Although a definition of trust could be described as, “a state of readiness for unguarded interaction with someone or something” there is a body of opinion that suggests there are three components that make up trust.

• The capacity for trusting.
• The perception of competence.
• The perception of intentions.

When you think of trust as being made up of these three components, it is much easier to understand. You can think about the capacity for trusting as your willingness to risk trusting other people. The perception of competence comprises your perception of your ability plus the ability of others to carry out their part of the task. Finally, the perception of intentions is your perception that the actions and words of other people are motivated by desires that serve all parties rather than being just self serving.

Productive and safety cultures require healthy levels of mutual trust because it is the basis of:

• Being able to rely on people
• Working as a team.
• Reducing risk.
• Having credible communication.

In larger organizations you cannot always control the level of trust that you experience, but you can act in seven ways that will create pockets of trust within your immediate work environment to create a safety culture if you carry out following.

1. You can hire and promote people to leadership positions who are capable of forming positive, trusting interpersonal relationships with their followers.
2. You can develop the skills of all your staff so that they are competent in interpersonal skills and emotional intelligence.
3. You can keep all your people truthfully informed. Let them know what’s going on.
4. You can be consistent under all circumstances. Your predictability will encourage people to trust you.
5. You can act with integrity and keep all your commitments. The moment you are unable to keep a commitment, you can explain what is happening without delay
6. You can respect every single staff member by listening and understanding first.
7. You can give positive reinforcement when it is due.

The moment you understand the invisible elements that underpin human behavior, you position yourself to achieve performance results you never thought possible. Through a greatly effective and more universally accepted change leadership approach, you may never have to use command and control again to experience behavior change.

WHY CHANGE RARELY STICKS

Whether you want to change your weight, change your relationship or change your company’s bottom line…it all comes down to human behavior.

You have no chance at sustaining improvements or changes in your business environment without first changing the underlying behavior and thinking patterns of the people involved. If you don’t address the behavior and thinking patters that created the existing situation in the first place, a time will come when you relax your regime of ‘change’ and everything will slip back to the way it was; back to the undesirable state.

See… the thinking and behavior patterns of your people are attuned to the status quo right now.

Take the example of a rubber band. To change the shape of the rubber band you could pull it and stretch it to a new shape. You could even hold it extended for a period of time in the shape you desire. But as soon as you let go it just snaps back into place, back into its original state. Your business is like this rubber band – it has an existing state that people are comfortable with. You can force these people into a new pattern of behavior but as soon as you relax your guard (which will happen sooner or later) they will begin to slip back into their old patterns.

It’s not your fault – suffice to say this is the greatest challenge business leaders face today; getting people to alter their behavior willingly and permanently.

THE COMMON ERROR IN LEADERSHIP

The most common error in leadership is to focus on managing people’s actions and use the power of authority to get them to change.

This outdated ‘Industrial Age’ approach is practiced widely. It is a model that involves managers using authoritarian based command and control methods to coerce staff into greater productivity and higher-level performance.

Granted, this method of leadership does have its place. However, in today’s social and business environment, if this is the only style employed it will not work! Without addressing the invisible elements of behavior, you will never successfully create lasting change. When an employee’s source of motivation is compliance or obedience, managers must remain vigilant and continually monitor behavior. If they don’t, the desired behavior will not last. Imagine your managers having to monitor employee work continually in an already busy environment. They have less time; more stress; and (in my experience) they also suffer a decline in the quality of their personal life. The change only persists if the managers keep up the monitoring effort.

Today your employees have the power of CHOICE, so authoritarian based models of influence are not without risk. If that is the only style used, your best staff will simply move on to find a more positive working environment where they will be engaged and challenged, not commanded. All you’re left with is the dead wood.

One of the most important things I have learnt in the past three decades of work is this:

All shifts in business results are preceded by a permanent change in behavior. All permanent behavioral changes are preceded by a step change in thinking…a PARADIGM SHIFT!

This understanding is what has set us apart from most service providers in our industry. We don’t focus our business growth and improvement efforts on KPIs alone or just the technical aspects of behavior. We positively shift those things that drive behavior first.

And we do it this way!

Check Out: How Effective Leaders Use Positive Reinforcement For the Greatest Effect

THE INVISIBLE ELEMENTS OF PERFORMANCE

The strength and effectiveness of Soarant Vision lies in our intimate knowledge of the 4 INVISIBLE ELEMENTS OF PERFORMANCE and how they can impact business at all levels.

Let me describe those four elements in this way.

The quality of the RESULT or OUTCOME you experience is determined by the quality of the actions or behaviors you engage in. Undertake the right behaviors and you create the desired outcome; it’s fundamentally as simple as that.

What determines the quality of the ACTIONS or BEHAVIORS you engage in?

Many people will think the answer is skill. I am here to tell you the quality of your actions and behaviors (within your potential performance range) is determined by the quality of your emotional state … yep, that’s right, determined by how you feel.

What determines whether your employee does or does not do something you want? Quite simply it’s determined by how they feel about it. Emotions drive all behavior; emotional state determines the quality of all behavior we engage in within a given range of performance potential.

To change the potential, you change the skill. To change the behavior, you must alter the emotional state.

Now… the final question. What determines the quality of one’s EMOTIONAL STATE?

I think we all know the answer to this one. The quality of one’s emotional state is determined by the quality of one’s THINKING and BELIEFS.

TWO AREAS OF IMPACT

Through understanding how these Invisible Elements of Performance can be shifted, we’ve been able to consistently experience exception results in two areas:

(1) PERFORMANCE GROWTH

Engaging people directly so they willingly shift their thinking and beliefs as a foundation to behavior change.

We put a ton of effort into this aspect of performance in our business execution workshops and leader development seminars. In fact, each seminar we deliver is designed to give people a set of skills and tools, but more importantly to have the right frames of reference and the vital sense of motivation to actually use the skills we teach.

Always remember… the thinking and motivational aspects of a new skill set can never be left unaddressed if you want people to use those skills.

(2) LEADER DEVELOPMENT

Coaching and developing leaders who can utilize the power of influence and persuasion to create permanent change without the stress they are accustomed to.

It takes time to develop influence and persuasion skills to the point where they can be utilized without thinking in any situation, but it is well worth the effort.

THREE SCENARIOS OF CHANGE LEADERSHIP

I’ve found there are 3 scenarios for which leaders must develop these change leadership skills.

Scenario 1: Informally influencing others around you to engage in some new behavior or respond to your requests. This can be at home or at work, and even upwards, downwards and sideways.

Scenario 2: Leading a change initiative and guiding people through a roadmap of change that involves a specific sequence of steps from planning through to locking the change in.

Scenario 3: Formally presenting to audiences in order to influence their behavior and generate some specific response to a request. Audiences can be of any size and both known and unknown to the presenter. This scenario is often a precursor to scenario 2.

I’d like to introduce a few truths and dispel some myths I’ve come to discover in my nearly two decades of working in the safety management arena. Some of these you will know of and agree with and some you won’t know and/or agree with. Either way, the article will have served the purpose of opening up a conversation about safety excellence. Even if the conversation is just going on internally in your mind, it’s a worthwhile exercise to challenge what we believe is true. Because of the limited space for the article, let’s start with some of the most popular myths and truths:

Myths

1. Excellence is Possible (and Highly Probable) – Perfection is NOT (and Highly Improbable)

Although it is highly popular in safety management to get our CEOs to sign off on a Zero goal commitment, it sets us up for inevitable failure. It is a much better plan to strive for excellence in creating safety than to expect perfection. Excellence is possible… perfect isn’t. There is a major problem with Zero Goals… they can be reached without being safe! See below.

2. Passing a Safety Audit Doesn’t Prove That Your Company is Safe

Most, if not all, of the popular audit instruments were created by well-meaning groups of people and are not based on any scientific evidence. Now, most of the questions in these audits are likely to be positives to your company outcomes but let’s examine a typical example question.

“Does your company have a signed Health & Safety Policy?” Arguably a good way to communicate your company’s intentions regarding the management of H&S. Problem is, the score. What is it worth. What are other questions in the audit worth toward your passing mark? Have they been measured in a test using control companies? If the scientific method has not been used to validate the audit… we must admit that we are just guessing. Some very unsafe companies can and do pass audits. That being true, then this audit process is flawed. I’m not suggesting you abandon your audits… I am suggesting you read the results with a clear view of what the audit score may not be telling you about your safety management system.

Check Out: 10 Essential Components For a Safer Working Environment

3. Doing Safety TO Your Employees and Contractors Give You Poor to Mediocre Results

As companies mature and strive for safety excellence, they almost universally realize that the model of “the few controlling the many” plateaus their safety results. Supervisors and managers cannot and should not take the place of full engagement of your employees (and contractors) in their own safety. When talking with those companies who have indeed reached safety excellence, they will all tell you that in their evolution to excellence, there came a point where they had to give it back to their employees. Doing safety with people has been proven to enhance your outcomes. People support what they had a hand in creating.

Truths

1. When your employees tell you it’s a safe place to be… it’s safe

Given the opportunity to honestly provide feedback about a company’s safety process, workers are great sources of information. Usually done anonymously to reduce any feelings of reluctance because of perceived negative consequences, perception surveys are wonderful sources of information. Workers really know what is happening in your company. If it doesn’t match your company’s intentions, then there is a gap that is clearly an improvement opportunity.

 

2. Low Injuries Rate Can (and often do) Mean Nothing as Proof of Safety

Measuring safety by the lack of injuries is just not valid. It is true that very safe companies have very few injuries… but it is also true that some very unsafe companies can and do work long periods of time without any injuries. This makes measuring safety by the lack of injury reports a very poor tool. What can be measured is the act of being safe. See the next point… Safety can be observed and measured.

3. Safety can be observed and measured

There’s no need to count injuries or damage to prove the existence of safety in your organization. This can be easily done through discussions and actually observing the work place for behaviors and conditions. We call these observations “leading indicators”. They serve us well as predictors of success (and sometimes failure). Either way, these leading indicators can help us focus on what needs to continue to be done or to be altered if we are unhappy with the observations.

Check Out: Measuring Workplace Health and Safety Performance

Well there you have it, a few Myths and Truths about safety management. I hope that this article helps you to reflect a little on what we believe and why we believe those things. After all, what we believe helps to drive our behavior and our behavior is what helps to make ourselves and others safe.

I remember only too well my first visit to a warehouse for a job interview. The bustle of the forklift traffic was considerable. Drivers were busily unloading and loading pallets of product into the long lines of waiting semi-tractor trucks. Numerous other employees were pulling and pushing hand trucks full of boxed product. This was one busy place. The natural question for me to ask as we continued our tour was, “Are your forklift operators trained?” I received the answer I was hoping for. “Oh yes of course!” My host continued to tell me, “We do it in-house and developed our own program and can’t drive the equipment here until they pass the test!”

On the surface, this looked and sounded wonderful. The company had recognized the considerable hazard untrained operators could create and had diligently attended to the hazard through a commonly accepted “administrative control” of a recognized hazard: operator training. As we proceeded from the loading dock into the storage area of the warehouse where three-story material racks were filled with palletized product, I was horrified to see that the base legs on nearly every one of the storage racks had been bent. The damage was seriously compromising the safety of the storage rack structure.

What this employer had failed to do was validate the behavior that they had hoped to accomplish with the forklift operator training. This is a common shortcoming of occupational health and safety related training. We set out the learning objectives and develop and deliver our safety courses.

On occasion, we even test the participants. Then many of us go on to the next safety issue if since our workers passed the knowledge test and demonstrated a level of competency at the time of the test that we’re now duly diligent and that they will forever more perform the tasks perfectly.

Really? By now we should all recognize that safe behaviors must be observed and re-enforced through positive feedback and, when necessary, the safe behavior coached.

How to make training “sticky”

For safety training to be “sticky” and result in safe behavior, we must take the often-overlooked step in training, which is validation. Case in point, Most Workplace Hazardous Materials Information System (WHMIS) programs I’ve seen are great at imparting the basic information regarding chemical hazards and most are diligent enough to ensure that all our workers can pass a written or verbal test of the many symbols and terms used on labels and Safety Data Sheets (SDS). We fall short of the mark, however, by not actually observing them working safely with chemicals. This is, of course, the behavior we desire, isn’t it? Ask yourself: When do these workers receive their WHMIS cards announcing to any future employer and us that they are WHMIS trained? Usually they get that card after they have passed a test of the symbol knowledge. This is hardly enough to certify that they can work safely with chemical products.

Check Out: Making Behavior Change Stick Through Effective Change Leadership

Training and the safe behavior model

The behavior change model of training requires the following steps to be completed:

Establish the desired behaviors. Write a performance-based behavioral learning objective that describes the desired behavior; under what conditions the behavior will be demonstrated and finally, the standard that must be achieved to be considered successfully competent. For example:

“At the end of a six-hour in-class training session the student will be able to perform the following behaviors at the student’s regularly assigned workstation:

1) Transfer liquid chemicals without over exposure to the chemical;

2) Read and explain the contents of four randomly selected SDS’c including:

1. a) What the entry routes are for the chemical;
2. b) What personal protective equipment (PPE) to wear;
3. c) Show knowledge of where the PPE is located;
4. d) Wear the prescribed PPE properly…

I think you get the idea… We need to describe under what conditions the employee will be demonstrating the behavior or competency.

Finally, we must demand that the student demonstrate the new behavior to a determined level of competency. Once a student has demonstrated their ability to meet the criteria, we must then continue to support the new behavior with consistent observation and feedback.

Mager’s theory of behavioral objectives

There are many theories and approaches to writing learning objectives, however I find the Robert F. Mager model the easiest to teach. I recommend that you read his book, “Preparing Instructional Objectives: A Critical Tool in the Development of Effective Instruction”.

Once the training needs are analyzed and the learning goals of the program are determined by establishing the desired future behavior, follow the steps of Mager’s approach.

Learning goals need to be broken into a subset of smaller tasks or learning objectives. By definition, a behavioral objective must have three components: behavior, condition and standard.

To learn more about Mager’s theory of behavioral objectives, check out this post at Convergence Training.

Validation is due diligence

Here’s where the proverbial rubber hits the road. Is the trained employee behaving to the trained standard? How would you know? By testing at the end of the course? Certainly, that would be an indication that the employee could do the behavior. The due diligence question that the courts will want to know is “Were they exhibiting the safe behavior and how did you know?”