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PETERSEN'S PAGE: Safety's balancing act

March 2, 2006
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This is the third in Dr. Petersen’s series applying lessons from best-selling books to safety, following Built to Last by James C. Collins and Jerry I. Porras in January, The Vision of the Anointed by Thomas Sowell in February, and now The Death of Common Sense by Philip K. Howard.

Have you been forced at some point to decide between safety or compliance — versus safety and compliance? The Death of Common Sense provides examples of the dilemma facing many businesses. The drive to improve safety should be internal, not external. Outside thrusts are often misdirected. Yet according to author Howard, several hundred billion dollars have been spent by industry to comply with OSHA’s 4,000 detailed regulations.

The Death of Common Sense raises these key questions:

  • Are safety and regulatory compliance synonymous?
  • Does complying with regulations ensure a safe operation?

    National Safety Council (NSC) statistics suggest that between 1926 and 1961, the country’s all-industry, lost-time frequency rate improved 80 percent. From 1961 to 1980, however, the rate deteriorated 133 percent. It then improved between 1980 and 1985, yet from 1985 to the present, it seems to have regressed.

    Studies of the relationship between an organization’s audit scores (which primarily assess regulatory compliance) and its injury record invariably indicate a near-zero correlation over time, in large companies that generate sufficient injury numbers to be believable.

    A waste of time?

    Do these studies prove that regulatory compliance is a waste of time and money in terms of reducing injuries? No, yet they suggest that the relationship should be more closely examined. Such studies also question whether adherence to a standard has any result other than causing a company to spend money.

    Even if one assumes that regulatory compliance leads to fewer injuries, will this positive trend continue? Will compliance continue to be cost-effective? Arguments over OSHA’s aborted ergonomics standard centered on these questions.

    The agency suggested that a high percentage of injury/illness problems are related to cumulative trauma disorders (CTDs) caused by repetitive motion. While some claim CTDs account for 40 to 60 percent of workers’ comp losses, you must realize that these percentages may only apply to illness claims, which account for only three percent of total injury costs.

    An ergo standard could have required a massive expenditure of corporate time, effort and money to reduce the probability of claims accounting for perhaps only 1.5 to 2.0 percent of safety’s financial problem. In addition, all this discussion assumes that CTDs are work-related, when, in fact, other factors — age, hormonal changes, worker attitude — are involved.

    Out of touch?

    What is the public perception of the government’s approach? And by extension, what is the public perception of safety professionals? A 1994 article, “Where’s OSHA When We Need It?” by two homemakers, Kim Manning and Leila Miller, argued that the government had gone overboard with regulations for a quarter-century and that safety practitioners must be equally out-of-touch to favor such activity.

    A dozen years later, OSHA emphasizes a more cooperative approach and standards-setting has cooled off. But still, safety management (and general management) and government activities are often opposite. Management says, “Let’s work together (management and labor) to solve problems,” to which government inspectors reply, “Thou shalt do what we say — or else.”

    Today’s safety professional faces the same challenge as decades ago: Counsel a company to comply with all regulations, even if compliance will not produce desired results. Research shows that no one right way to achieve safety exists. What works at one company will likely not work as successfully at another. Yet, regulatory guidelines state the opposite.

    Companies are implementing new management concepts and achieving positive results. Some are incorporating safety into quality management processes; some are integrating safety into management systems as never before; others use statistical process controls; still other use various positive reinforcement techniques and approaches; many use new measures and rewards for proactive safety performance.

    So we have the safety professional’s balancing act: Build managerially and behaviorally sound safety systems and join the upper management team, while pursuing regulatory compliance requirements.

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