Changes in safety and health approaches are needed both in and outside of government. Many established beliefs and assumptions concerning government operations currently are being re-evaluated and questioned. This reset presents an opportunity. New, preventive approaches rely on learning more than punishment, assess capacity and resilience rather than simply track failure, and focus on the organizational and human factors likely to impact the risk of fatalities and serious injuries.
Time for soul searching
The current OSHA model has been in place for more than four decades, with relatively little modification. Times have changed, business processes have changed, and workers have changed. OSHA’s approach to prevention has not kept up.
The focus of OSHA and the safety and health community must evolve from tracking failure and emphasizing strict compliance and punishment to an emphasis on reducing risk, driven by increased collaboration and shared learning.
- To be perceived as fair and reasonable, citations and penalties should be limited to serious hazards. OSHA should stop issuing citations for trivial technical violations. Most non-serious issues can be addressed by advising employers of what they need to correct. An advisory group could develop a list of examples of violations that would not be cited.
- OSHA rule making and guidance development should move toward risk-based, performance standards. These standards will keep pace with rapidly changing technology and management practice. Negotiated rulemaking should also be used to foster collaboration.
- OSHA should require, and the profession promote, key safety and health program elements. OSHA should promulgate a performance-based standard specifying key elements of a safety and health management system. Compliance should be kept flexible; the requirement should relatively easy to understand and implement, especially for small and mid-size employers. Conforming to one of the recognized safety and health consensus standards or creating internal safety and health management systems could constitute compliance.
OSHA’s Recommended Practices for Safety and Health Programs, released by in 2016, could be the basis for a performance-based standard focused on key core elements. ANSI Z10 and the new ISO 45001 also can guide OSHA in developing its safety and health management system standard.
- OSHA data should be improved and supplemented. Key leading indicators should measure the content and quality of the prevention process. Current data on occupational injuries and illnesses are limited and do not meet the needs of OSHA or the safety and health profession.
- The agency should schedule inspections based on accurate assessment of the risk and potential harm employees face. Both OSHA consultation and compliance should be targeted based on relative risk: the potential severity of the hazard, the magnitude of exposure (number of workers exposed and duration of exposure), and the likelihood of injury or illness as determined by the type, strength, and health of controls in place.
The inspection weighting system should be redefined to better direct that focus. Remove non-formal complaints from the weighting system. OSHA could also create a risk profile of priority sites and processes. First identify those that involve well-known serious hazards, then refine the selection process by cross-referencing those data with aggregated inspection findings for each industry, utilizing inspection profiles for companies and/or sites in those industries.
- Worker safety and health efforts must be seen as business enablers, rather than barriers to performance. Yet many business leaders still view safety and health programs and related expenditures as costs to be minimized whenever possible Safety and health professionals must become proficient at understanding how their issues relate to business, and how to communicate to management the advantages of eliminating and controlling hazards.
- We need to do more to help our businesses understand risk. Traditional risk assessments focus on the severity of the hazard and the likelihood of an event. Likelihood is often based on subjective criteria, including past OSHA injury and illness rates. Aside from the well-known lack of reliability of those data, a study by the Rand Corporation indicates that such data are not good predictors of the most serious cases ‒ those that result in a fatality.
Traditional approaches to incident investigations, which often look for a single root cause and focus on determining who, instead of what, was responsible, are grounded in the belief that most injuries and illnesses are caused by humans who are either poorly trained, negligent, or intentionally disregarding work rules. This leads to blaming, shaming, and retraining ‒ or punishing ‒ injured workers. Instead, find and fix system attributes that are the real drivers of the actions at the center of most serious incidents.
- Accountability needs to distinguish errors and mistakes from intentional violations. Experts such as Todd Conklin and Sydney Dekker agree that the key to understanding safety and health incidents lies in understanding work as performed and the organizational and systems factors that impact that work, Front line employees must be engaged and listened to. This is unlikely in operations that emphasize blaming, shaming, and punishing them.
- Expand the prevention focus in many companies beyond OSHA compliance. Leverage effective practices and include a more robust understanding of and emphasis on risk. For example, some companies define an acceptable level of risk for the enterprise and calibrate standards, procedures, and behaviors accordingly. This requires more than focusing just on specific hazards and controls; understanding the organizational context in which employees work with hazards is also critical.
Risk is heavily influenced by organizational characteristics and human factors. Yet it seems much easier to “fix” an employee who seemingly made a misstep than address organizational issues that lie at the heart of the problem.
The opinions expressed here are solely those of ORC HSE and do not reflect the opinions of individual ORC HSE member companies -- more than 100 large multinational corporations. For a copy of the complete ORC HSE White Paper visit : http://www.orchse-strategies.com/about-us/orc-hse-white-paper/