Kevin Ian Schmidt

Making Behavior Change Stick Through Effective Change Leadership

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This outdated ‘Industrial Age’ approach is practiced widely.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.

5 Rules of Workplace Safety Management

There are certain rules of human behavior that must be considered when developing a process of safety management. If you violate these rules, you will fail in your objective to develop a safer workplace. The rules themselves are simple, however, don’t be deceived because they have a great influence on human behavior.

Rules of Workplace Safety Managemet

  • Repetition: To get your message across it is necessary to use repetition. Repetition will ensure that your safety message is at the top of every employees’ consciousness. Safety management is a process not an event. One of the ways to create this consciousness about safety is to hold five-minute safety briefings at the beginning of each shift. This is very similar to a game plan which is discussed before a sports team takes the field. If you make the safety briefings relevant, interesting and valuable, you will find that staff members will contribute readily.
  • Consistency: The concept of consistency applies to many situations and has a profound effect on human behavior. We trust people who are consistent, we believe their message, in turn we will tend to be more trustworthy and consistent. Consistency is demonstrated. For example, if, at a safety briefing you mention that there will be no blame should an accident occur, the statement must be backed up by your behavior and the behavior of others in the event of an accident.
Check Out: How to Improve Your Safety Culture
  • Involvement: Involvement is the key to safety management. To gain control, you must give control. The people who are ideally situated to develop safe working practices are the people doing the job. This contrasts with the normal prescriptive safety management process where somebody, somewhere creates rules and regulations without the experience of doing the job. Every single person on any work site should be able to contribute to safe working practices. If you avoid this basic principle, you will find that the imposed “safe working practices” will be ignored.
  • Positive reinforcement: The number one tool in safety management is positive reinforcement. If you are serious about creating a safer workplace, make sure that you recognize safe behavior. Every day go on a mission to find people who are working safely and tell them that you have noticed what they are doing. This is harder than it sounds. Try it and find out for yourself. But remember, the results are well worth the effort. Catch your people doing it safely and they will continue to do it safely.
  • Common sense: It has been said that sense is not that common. This is relevant when considering workplace safety management. If the safety rules and regulations don’t pass the common sense of the people at risk, they will not comply. That’s why the involvement of the staff in safety management is so important.

 

 

10 Tips to Improve a Safety Management System

If you are looking to take your system to the next level, the following ten things will help you improve your safety management system and will help you with your journey:

  1. Defining safety roles and responsibilities for all levels of the organization. For example, ensuring that safety is a line management function and not part of the safety professional’s role.
  2. Developing upstream measures. Stop focusing on OSHA’s Total Case Incident Rate (TCIR) as a measurement. For example, document and track the number of reports of hazards/suggestions, number of committee projects/successes, number of related specific activities, etc.
  3. Ensure that management and supervisors are aligned with the vision, by establishing a shared-vision of safety goals and objectives vs. production, quality, etc.
  4. Implementing a process that holds managers and supervisors accountable for visibly being involved where they will set the proper example and leading a positive change for safety.
  5. Evaluating and rebuilding any incentives and disciplinary systems for safety, as necessary. For example, not basing the incentives and disciplinary system on the number of recordable injuries. Instead focus on specific activities that have been performed.
  6. Ensuring that all safety committees understand their roles and responsibilities, have a defined charter, and are functioning properly. For example all employees should know how to become a member of a committee, understand their responsibilities/functions, and authority.
  7. Providing multiple paths for employees to make suggestions, concerns, or problems. One such mechanism should use the chain of command and ensure that there are no repercussions against employees. The key is to track suggestions, concerns, and/or problems and hold supervisors and middle managers accountable for being responsive to all employee concerns.
  8. Developing a system that tracks and ensures that there is timely hazard correction. Many sites have been successful in building this in with an already existing work order system.
  9. Ensuring that there are methods for reporting injuries. Educate employees on the importance of reporting minor injuries and loss producing events. For example, first aid cases and any near misses.
  10. Evaluating and rebuilding the injury investigation system as necessary to ensure that investigations are conducted on a timely basis, complete, and effective. Ensure that each injury has an identified root cause. Avoid blaming employee for injuries. Take a look at the management system as a whole to see if there was a failure in the system.

As stated, if you are looking to take your safety management system to the next level, the listed ten items will help you with the needed improvement along your with your journey.

Some Myths and Truths About Safety Management

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.

  1. 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
  1. 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.

 

  1. 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.

  1. 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.

Safety Training Is About Behavior Change

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?”

Hazard Communication Plan Explained

More than 30 million workers in the United States are potentially exposed to one or more chemical hazards. There are an estimated 650,000 existing hazardous chemical products, and hundreds of new ones are being introduced annually. This poses a serious problem for exposed workers and their employers.

The Hazard Communication Standard (HCS) is now aligned with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). This update to the Hazard Communication Standard (HCS) will provide a common and coherent approach to classifying chemicals and communicating hazard information on labels and safety data sheets. This update will also help reduce trade barriers and result in productivity improvements for American businesses that regularly handle, store, and use hazardous chemicals while providing cost savings for American businesses that periodically update safety data sheets and labels for chemicals covered under the hazard communication standard.

OSHA.gov

How does the OSHA Hazard Communication Standard effect your business? Well first let’s take a look at what OSHA sets as some standards.

The OSHA Hazard Communication Standard (HCS) – 29 CFR 1910.1200 provides workers exposed to hazardous chemicals with the identities and hazards of those materials,

From OSHA.gov

Hazard Communication Standard

spray-bottleIn order to ensure chemical safety in the workplace, information about the identities and hazards of the chemicals must be available and understandable to workers. OSHA’s Hazard Communication Standard (HCS) requires the development and dissemination of such information:

  • All employers with hazardous chemicals in their workplaces must have labels and safety data sheets for their exposed workers, and train them to handle the chemicals appropriately.

So you read this and say to yourself, “I don’t deal in hazardous chemicals”. But if you have things like cleaning chemicals, that employees or the public can handle, then you need to comply with OSHA’s Hazard Communication Standard. Employees need to be familiar with OSHA’s hazard communication standards to help save lives and avoid OSHA citations.

Purpose of the HAZCOM standard

The purpose of the HCS 2012 is to make sure that:

  1. the hazards of all chemicals produced or imported are classified, and
  2. information about the classified hazards is transmitted to employers and employees.

Classifying the potential hazards of chemicals, and communicating information concerning hazards and appropriate protective measures to employees, may include:

  • hazard communication plandeveloping and maintaining a written hazard communication program
  • listing hazardous chemicals present
  • labeling containers of chemicals in the workplace
  • labeling containers of chemicals being shipped to other workplaces
  • preparing and distributing SDSs to employees and downstream employers
  • developing and implementing employee training programs

The HCS 2012 applies to any chemical which is known to be present in the workplace in such a manner that employees may be exposed under normal conditions of use or in a foreseeable emergency.

Foreseeable emergency” means any potential occurrence such as, but not limited to, equipment failure, rupture of containers, or failure of control equipment which could result in an uncontrolled release of a hazardous chemical into the workplace.

The phrase “known to be present” is important. If a hazardous chemical is known to be present by the chemical manufacturer or the employer, it is covered by the standard.

Check Out: How to Read an SDS Sheet

This includes not using generic, unlabeled cleaners, or buying cleaners in bulk and putting them in unlabeled bottles. Using a marker on the bottle isn’t enough either.

“Hazardous chemical” means any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified.

This includes chemicals to which employees may be exposed during normal operations or in a foreseeable emergency. This means that even though an employer was not responsible for the manufacture of the hazardous chemical, the employer has the responsibility for transmitting information about the hazardous chemical to his or her employees.

Check Out: Hazard Communication Standard Training for Supervisors

Employees, such as office workers or bank tellers who encounter hazardous chemicals only in non-routine, isolated instances are not covered. For example, an office worker who occasionally changes the toner in a copying machine would not be covered by the standard. However, an employee who operates a copying machine as part of her/his work duties would be covered by the HAZCOM Standard.

Do you have all SDS sheets and a chemical listing of chemicals onsite, that is available to all employees, not locked in a drawer in a back office. Online access is acceptable, as long as all employees know how to get it and have access to a computer.

Have you conducted employee awareness training on how to read an SDS sheet?

 

Download and view a sample HAZCOM policy below; that can be adapted for your needs, but remember a small business owner might find a full and proper Hazard Communication Plan to be overwhelming to fully and properly design.

 

Sample_HAZCOM_program_final

First Aid Training and Kit Requirements

Does your business have a first aid kit? Do you have people in your business trained to render first aid?  What are the requirements for first aid kits, first aid training, and such according to OSHA?

1910.151(b)

In the absence of an infirmary, clinic, or hospital in near proximity to the workplace which is used for the treatment of all injured employees, a person or persons shall be adequately trained to render first aid. Adequate first aid supplies shall be readily available.

 

Near Proximity for First Aid Responders

first-aidSo first let’s talk about what OSHA means by “near proximity”, because that can be vague. In a workplace, where employees may be exposed to hazards, like machinery or powered equipment, a response time over 3-4 minutes in considered “near proximity”, and for an office setting, “near proximity” is deemed 15 minutes. This comes from the OSHA Letter of Interpretation from March 2007.

So how does this effect your workplace if you are a retail establishment? Do you have any machines employees use, baggers, cardboard compactor, steamer, or anything else? Then you should probably hold your business to the standard for a 3-4 minute response time. This holds true for a restaurant, where an employee could burn themselves severely.

Now, factor in that the national average response time for an ambulance in most urban environments is 8 minutes or MORE, and you soon realize, you would be outside of the OSHA standards for near proximity and should have trained first aid responders on site.

 

 

First Aid Kit Requirements

first aid kitHaving a first aid kit in the workplace is just a good safety precaution, even if you feel you aren’t required to under OSHA guidelines. It can become confusing though, because the OSHA Regulation, simply says “Adequate first aid supplies shall be readily available.” What is deemed adequate? What supplies must you have?

In an OSHA Letter of Interpretation from April 2002, Richard E. Fairfax, Director: Directorate of [Enforcement] Programs for OSHA talks of how the ANSI standard Z308.1-1998 would be deemed adequate for most small workplaces, but you should also have suitable supplies for the risks in your workplace.

ANSI standard Z308.1-1998 supplies

ANSI/SEA Z308.1 2009 – Minimum Requirements for Workplace First Aid Kits and Supplies Basic Kit – minimum contents.

 

ITEM MINIMUM QUANTITY
Absorbent compress, 32 sq. in. 1
Adhesive bandages, 1 in. x 3 in. 16
Adhesive tape, 3/8 in. x 2.5 yd. total 1
Antibiotic treatment,0.14 fl. Oz. (0.9 g) 6
Antiseptic,0.14 fl. Oz. (0.5 g) application 10
Burn treatment, 1/32 oz. (0.9 g) application 6
First-aid guide 1
Medical exam gloves 2 pairs
Sterile pads, 3 in. x 3 in. 4
Triangular bandage, 40 in. x 40 in. 56 in. 1

 

first-aid-kit-unstockedThis amount would be sufficient for a small workplace, with 2-3 employees, and then increase the amount of supplies as you increase employees, and also consider having one basic kit of bandages in the front of the business and a larger more comprehensive amount of first aid supplies in the back office.

If you plan on keeping your medical cabinet locked up in a back office, consider this OSHA Letter of Interpretation from January 2007, which says it is ok to lock the medicine cabinet up, but it must be accessible during an emergency. So, be careful with locking it up, because if it isn’t accessible when needed, it can result in a worse injury, and potentially trigger an OSHA inspection.

It is also important to note that if you have a first aid kit, and it is poorly maintained, OSHA could find you in Willful noncompliance, which could dramatically increase your fines.

 

First Aid Training and Bloodborne Pathogens Requirements

bodily-fluid-cleanup-kitIf you determine your business is required to provide first aid training, know that OSHA has requirements for providing Bloodborne Pathogen training along with it, as clarified by this OSHA Letter of Interpretation from January 2007.

So what does that mean for your business? Well, OSHA’s Bloodborne Pathogen Standard has specific rules as they relate to training, recordkeeping, and even offering Hepatitis B vaccinations.

Check Out: BloodBorne Pathogen Exposure Control Plan

One aspect of the Bloodborne Pathogen requirement that is often overlooked is a policy, written specifically that addresses workplace exposure risks, along with proper handling and cleanup of blood and other bodily fluids.

You also need the proper bloodborne pathogen cleanup kit, I you have bloodborne pathogen training for employees. Because like earlier, partially implementing a program or plan, could show OSHA you were aware of your requirements but didn’t follow through with them, and increase a citation to a Willful, and lead to much higher fines.

 

 

 

 

Guidelines for Investigation Interviews

Definition
Employee Investigation Interviews are set up to review claims made by employees regarding discrimination, harassment, violence, or other prohibited behaviors in the workplace.

 

The Investigation Interview Process

When you’re conducting employee investigation interviews, the interview process should be carefully planned, followed, and documented to help mitigate exposure to litigation. The sequence of interviews should generally start with the complainant, followed by the accused, and then any witnesses or other parties involved.

While there is no law mandating how quickly an investigation must begin, a good rule of thumb is to start the investigation within two business days of receiving the complaint. A prompt investigation will offer several advantages:

  • Memories are fresh.
  • Witnesses and other relevant parties will still be available.
  • Gossip or rumor mills are less likely to interfere with information.
  • Witnesses will less likely be tampered with or intimidated.
Check out my post Factors to consider in an investigative interview for more tips on the process

Documentation

Take detailed notes during each interview. Make sure you are only documenting factual information and observable facts about the interviewee’s behavior and demeanor during the interview. Avoid assumptions or opinions about what is said or what you believe to have happened. Stay away from documenting subjective conclusions based on the interviewee’s behavior or demeanor during the interview. Notes should include the following:

  • Administrative details such as name, job title, and date of interview
  • Warning statements such as “keep information confidential,” “no retaliation,” etc.
  • Key factual points of the interview
  • Non-verbal expressions like tears, failure to look interviewer in the eye, and nervous affectations

Maintain all documentation related to the investigation in a separate, confidential file apart from the employees’ general personnel files. Limit access to investigation files to only those with a legitimate need to know.

Check Out: Effective Communication Skills – NONVERBAL

Questioning Techniques

Prepare questions in advance:

  • Ask who, what, where, when, why, and how.
  • Ask questions that require events be stated chronologically. This allows the investigator to compare different versions of the story.
  • Although you should plan your questions in advance, additional questions may arise based on the information you gather. Don’t limit yourself to the planned questions; ask follow-up questions to clarify.

Keep these few tips in mind when interviewing:

  • Begin with open-ended questions, then transition to more detailed, specific questions.
  • Avoid asking tough questions first; start with simpler questions to put the interviewee at ease.
  • Ask one question at a time and do not move on to the next question until you have all the information needed. Do not interrupt.
  • Ask for specific examples.
  • Remain neutral; don’t formulate an opinion before all the facts have been gathered.
Check Out: Effective Communication Skills – LISTENING

Interviewing the Complainant

When you begin the interview, state the purpose of the meeting and restate relevant company policy. Inform the complainant that the company takes all complaints seriously and will conduct a prompt and thorough investigation. Thank the complainant for bringing the matter to the company’s attention and assure the person the information will be confidential to the extent possible.

Ask for a full explanation of the situation. Ask specific questions such as:

  • What happened?
  • Who said what?
  • Where did the incident take place?
  • What time did it happen?
  • Who was present?

When concluding the interview, ask if there were other witnesses; document the response even if the complainant says no. Summarize the interview with the complainant and have the complainant confirm that it is accurate. Document the response to the confirmation question. Instruct the interviewee to provide any additional information that may not have been covered. Remind the interviewee that all information should be kept confidential. And last, but definitely not least, reiterate the no-retaliation policy, telling the interviewee to report any retaliation incidents.

Interviewing the Accused

When you start this interview, let the accused know that you are conducting an investigation of wrongdoing on behalf of the employer and that he/she is the subject of the investigation. Inform the individual of the accusations so the accused can respond and reiterate confidentiality and no-retaliation policies.

Ask the accused for a response to the allegations of wrongdoing; ask clarifying questions about who, what, where, when, and how the incident occurred. Ask if the accused understands the company policy regarding the situation. Also, ask if there is anyone who can corroborate the accused’s story.

When you conclude the interview, ask the accused if there were any witnesses. Summarize the account just provided and have the accused confirm the account is accurate as it was told. Ask the accused to report any additional information that comes to mind after the interview is over. And last, remind the accused of the confidentiality of the information provided and the no-retaliation company policy.

Interviewing the Witnesses

When you are ready to interview any witnesses, make sure you talk to each one individually. Explain the purpose of the interview and ask the witness for any information about the situation. At the end of the interview, remind witnesses of the confidentiality of the information provided and the no-retaliation policy.

When you conclude the interview, ask the witness if there is anyone else the interviewer should talk to; document the answer, even if it is no. Summarize the witness’s statement and confirm with the witness that it is accurate as reported.

Interviewing each person thoroughly and carefully in an employee investigation is critical to getting the facts – from all involved – correct. Remember, someone’s job or life could be adversely affected by the outcome of your investigation. Do your very best to conduct unbiased and clear interviews.

 

These investigation interview tips will help keep you sharp, but if you need professional assistance, or want to conduct a training for your staff, please feel free to contact me.

Fire Prevention Plan – Overview

The purpose of a Fire Prevention Plan is to eliminate the causes of fire, prevent loss of life and property by fire, and to comply with the Occupational Safety and Health Administration’s (OSHA) standard on fire prevention, 29 CFR 1910.39. It provides employees with information and guidelines that will assist them in recognizing, reporting, and controlling fire hazards.

A quality Fire Prevention Plan describes the fuel sources (hazardous or other materials) on site that could initiate or contribute both to the spread of a fire, as well as the building systems, such as fixed fire extinguishing systems and alarm systems, in place to control the ignition or spread of a fire.

 

OSHA Guidelines for a Fire Prevention Plan

A fire prevention plan must be in writing, be kept in the workplace, and be made available to employees for review. However, an employer with 10 or fewer employees may communicate the plan orally to employees. [29 CFR 1910.39(b)]

At a minimum, your fire prevention plan must include:

  • A list of all major fire hazards, proper handling and storage procedures for hazardous materials, potential ignition sources and their control, and the type of fire protection equipment necessary to control each major hazard. [29 CFR 1910.39(c)(1)]
  • Procedures to control accumulations of flammable and combustible waste materials. [29 CFR 1910.39(c)(2)]
  • Procedures for regular maintenance of safeguards installed on heat-producing equipment to prevent the accidental ignition of combustible materials. [29 CFR 1910.39(c)(3)]
  • The name or job title of employees responsible for maintaining equipment to prevent or control sources of ignition or fires. [29 CFR 1910.39(c)(4)]
  • The name or job title of employees responsible for the control of fuel source hazards. [29 CFR 1910.39(c)(5)]
  • An employer must inform employees upon initial assignment to a job of the fire hazards to which they are exposed. An employer must also review with each employee those parts of the fire prevention plan necessary for self-protection. [29 CFR 1910.39(d)]
Learn how to conduct a Fire Risk Assessment to best formulate your Fire Prevention Plan

A Fire Prevention Plan serves to reduce the risk of fires at your workplace in the following ways:

  1. The Fire Prevention Plan identifies materials that are potential fire hazards and their proper handling and storage procedures.
  2. It distinguishes potential ignition sources and the proper control procedures of those materials.
  3. The plan describes fire protection equipment and/or systems used to control fire hazards.
  4. It identifies persons responsible for maintaining the equipment and systems installed to prevent or control ignition of fires.
  5. The Fire Prevention Plan identifies persons responsible for the control and accumulation of flammable or combustible material.
  6. It describes good housekeeping procedures necessary to insure the control of accumulated flammable and combustible waste material and residues to avoid a fire emergency.
  7. The plan provides training to employees with regard to fire hazards to which they may be exposed.

 

Fire Risk Assessment

Prior to fighting any fire with a portable fire extinguisher you must perform a fire risk assessment that evaluates the fire size, the fire fighters evacuation path, and the atmosphere in the vicinity of the fire.

Check Out: Fire Extinguisher Basics
Risk Assessment Question Characteristics of incipient stage fires or fires that can be extinguished with portable fire extinguishers Characteristics of fires that

SHOULD NOT be fought with a portable fire extinguisher (beyond incipient stage) – evacuate immediately

Is the fire too big? The fire is limited to the original material ignited, it is contained (such as in a waste basket) and has not spread to other materials. The flames are no higher than the firefighter’s head. The fire involves flammable solvents, has spread over more than 60 square feet, is partially hidden behind a wall or ceiling, or cannot be reached from a standing position.
Is the air safe to breathe? The fire has not depleted the oxygen in the room and is producing only small quantities of toxic gases. No respiratory protection equipment is required. Due to smoke and products of combustion, the fire cannot be fought without respiratory protection.
Is the environment too hot or smoky? Heat is being generated, but the room temperature is only slightly increased. Smoke may be accumulating on the

ceiling, but visibility is good. No special personal protective equipment is required.

The radiated heat is easily felt on exposed skin making it difficult to approach within 10-15 feet of the fire (or the effective range of the extinguisher). One must crawl on the floor due to heat or smoke. Smoke is quickly filling the room, decreasing visibility.
Is there a safe evacuation path? There is a clear evacuation path that is behind you as you fight the fire. The fire is not contained, and fire, heat, or smoke may block the evacuation path.