EHS: A Risky Future

December 17, 2004
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Dear Subscriber,

In our last edition of ISHN's e-newsletter, we asked for your comments on the need for, and possible criteria of, a national award for environmental health and safety.

Several responses pointed out a snag: EHS pros can't agree on how to measure EHS excellence — unlike well-known financial measures that define business winners and losers.

Executives will not understand or even care about superior EHS performance until EHS pros reach some kind of agreement, wrote Richard MacLean in an article in Environmental Quality Management.

"I don't see any spark of interest in a Baldrige type award for safety," said David Varwig, a CSP with 30-plus years experience in the nuclear industry.

You can't judge what you can't measure. Said Varwig: Would someone please tell senior managers exactly what they are supposed to be doing for safety? Uniform safety program descriptions are needed — including formalized expectations for senior managers, safety people, supervisors and employees.

Safety's problem with definition and documentation actually runs deeper. We received a strong comment criticizing the lack of a uniform performance standard for professionals themselves. "We cling to the notion that some of us are 'engineers.' In a pig's eye!" said a safety and environmental coordinator with 28 years experience. "My son, a P.E. in civil engineering, says we are thieves and liars, with a 'gotcha dad' look in his eye."

CONFLICTED OVER STANDARDS

Here's the rub — it's an attitude that gets in the way not only of a national EHS award, but greater credibility for the professional as a whole. EHS pros have conflicted feelings about standards and standardization. Yes, they have shaped the profession, but… especially in recent years, the mind set has been: The fewer standards from OSHA, ISO, etc. the better. Let us figure it out.

For example, the American Society of Safety Engineers recently weighed in with a position statement on the need for an ISO social responsibility standard.

In a letter to the American National Standards Institute, ASSE wrote: "… a standard on social responsibility would be difficult to develop, implement, advocate, and finally ensure compliance…"

Déjà vu all over again? Almost identical words have been used to refute the need for many an OSHA standard — ergonomics, a safety and health program management rule, motor vehicle safety, indoor air quality to name a few.

Instead, ASSE argued to leave social responsibility alone and let each "company's business culture" use its own policies, procedures and practices to come up with something.

Which is basically the same argument U.S. companies used to reject a proposed ISO safety and health management system standard in the late 1990s.

LEAVE IT TO THE ELITE?

This disdain for standardization certainly fits the American culture of individualism. And it does benefit some individual EHS pros, allowing them freedom and flexibility to run their own shops as they see fit.

But here's the catch. As a 1997 paper drafted for the Center of Strategic & International Studies concluded after interviewing 17 business execs, the fate of EHS funding, staffing and investment decisions rests on "the skill of the individual championing them."

In other words, the absence of widely accepted performance and best practice standards — such as found in accounting, medicine, law and engineering — leaves EHS as a business function wide open to whims and judgment calls. One business manager interviewed in the paper said EHS investment decisions come down to questions such as, "What's your gut feel?" "Is this the right thing to do?"

Not exactly sound science to protect lives and property. Imagine being wheeled into surgery and overhearing your surgeon say to another doc, "What's your gut feel?" Or having your home built and hearing the architect wonder, "Is this the right thing to do?"

What's noteworthy about the process of EHS decision-making, according to Terry F. Yosie and Timothy D. Herbst, authors of the paper, "The Journey Towards Corporation Environmental Excellence," — http://www.csis.org/e4e/yosiepg.html — is the absence of the "business mind set."

The upshot? If you're not fortunate to have a savvy, well-connected EHS champion hard at work for you, an EHS management system risks becoming a marginal, maintenance activity, say the authors.

Without recognized standards of excellence, best practices, and a scorecard of metrics beyond OSHA recordables, most EHS programs achieve only modest results based on the pursuit of incremental improvements, rather than seeking more strategic and significant breakthroughs and innovations, according to the authors.

When was the last time the EHS field was truly rocked by a programmatic innovation? Behavior-based safety, one could argue. And why BBS? Because organizations needed a standardized method to manage organizational behavior.

CRACKS IN THE EHS CULTURE

The rate of injuries and illnesses declined from 5.3 cases per 100 full-time workers in 2002 to 5.0 in 2003, the Bureau of Labor Statistics announced this week. Though year to year comparisons are no longer possible due to changes in recordkeeping practices, it's still remarkable to look back 30 years to 1973, when the total case rate was 11.0. In manufacturing, the total case rate has plummeted from 15.3 in '73 to 6.8 in 2003.

This progress has come despite many gaps in EHS standardization. Consider:

  • No uniform safety program descriptions exist.
  • No uniform safety responsibilities and expectations for managers, supervisors, and employees exist.
  • No consensus elements of an EHS management system have been accepted.
  • No consensus has been reached on the competencies required of EHS pros. No definitive skill set for pros has been established.
  • No widespread enforcement of EHS credentialing exists. There are scores of credentials.
  • No definitive threshold for superior safety performance has been established. "You know it when you see it," said one safety pro.
  • No definition of EHS excellence has been accepted.
  • No definitive scorecard of EHS performance metrics has been developed to replace the mismash of critical and mundane measures.
  • No agreement on the economic benefit of EHS investments has been reached beyond intuitive declarations, and no uniform valuation of EHS has been documented.

"See, we don't need any thresholds, cookie-cutter formulas, or restrictive requirements," some EHSers would say, admiring decades of falling numbers.

Of course, supporters of standards would note that the great decline in injuries and illnesses occurred during the decades when OSHA rolled out a steady stream of standards. Would such progress have been possible without the OSHA rules?

POSSIBLE BUILDING BLOCKS

But this edition of ISHN's e-newsletter is not a debate about standards, are they good or bad for the EHS field? It's about the future growth of the field.

It is a future that cannot be build by depending on a small group of individual champions to push EHS forward. It can't be guaranteed by relying on a handful of world class business cultures to do the right thing. The future can't be left to judgment calls and gut feelings and hopefully creating an air of excitement about EHS.

Heading into a new year, here's hoping some potential building blocks of EHS's future get more attention and discussion than they have so far. They are not perfect solutions, some are works in progress, but at least they take a crack at consensus-building and innovation:

  • ANSI standard Z490 — Criteria for Best Practices in Safety, Health and Environmental Training.
  • ANSI standard Z590 — Competence and Certification in the Safety Profession, including criteria for establishing the scope and functions of the professional safety position and accepted practices for audits, assessments and evaluations.
  • ANSI standard Z10 — Occupational Health and Safety Management Systems, which spells out expectations for management leadership, employee participation, and itemizes the elements of a health and safety system.
  • Follow up to the "Economic Evaluation of Occupational Health & Safety Interventions at the Company Level" symposium organized by NIOSH and the World Health Organization this past November. The goal: demonstrate economic gains from health and safety interventions. Let's hope it gets more traction than the 2001 and 2002 Workplace Safety Summits at Georgetown University.
  • Completion of the Organization Resources Counselors' occupational health and safety performance metrics manual.

Dave Johnson is the ISHN E-News editor. He can be reached at djsafe@bellatlantic.net, (610) 666-0261; fax (610) 666-1906.

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WE NEED YOU!

Are you a safety and health pro or a manufacturer or provider of occupational safety and health products or services who enjoys writing?

Shakespeare need not apply, but ISHN is looking for authors to publish short articles (1,000 words) in our monthly issues.

Topics include: safety success stories, close calls and personal experiences, training tips, use of software, engineering controls (machine guards, lockout-tagout), gas detection and air monitoring, confined space safety, personal protective equipment, and OSHA compliance issues.

If any of these topics interest you — or if you have other ideas — e-mail editor Dave Johnson at djsafe@bellatlantic.net

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