Just read Mr. Rosenblum’s email on “transparency.” Give him credit for creative thinking. But, I have some comments and mean no disrespect.

• The premise is that the public cares about an organization’s safety performance and will predicate their purchasing based on that perception. Using a bell curve, I’d say a segment of the population might care, most will not give it much thought, and the last segment absolutely won’t care. Why? Because people are self-centered. They want the best bargain or the best value.
  
  
• OSHA is the organization to pull this off. That is a really not possible. Their rule-making process is slow, they can not get consensus on even the most fundamental of safety issues and their charter is a rule-making/enforcement agency. It is folly to think they would be the organization to not only develop, but manage such a mega-project, along with their compliance function.
  
  
• Who is going to set the criteria for entry into this elite group? Who will agree with the criteria? Moreover, who is going to audit/analyze who makes the cut? OSHA does not have the staff to do this. The qualifications for this type of assessment require a different skill set than that for a CHSO.
  
  
• Do organizations remain static? They are always changing – most frequently due to leadership changes. For example, for the last half of 2010 a company makes the grade. Then things change and this year, they are not so qualified, but they have the seal of approval garnered last year. Who will know of the slide from great to good? No one, but they still have the seal of approval.
  
  
• Will a larger organization with multiple facilities or sites require multiple seals of approval? Surely we know that each location has its own culture and ways of operating. Will a company whose parts are made at an unqualified site, but assembled an exemplary site make the cut or will this disqualify the entire organization?
  
  
• The information will be posted on the internet, but who devote the time to access the internet for safety performance information before buying a product? Again, the bell curve will predominate.
  
  
• The rating will take all the factors into consideration and roll them up to a single figure. Clearly, an attempt at simplicity, but measuring safety performance is not that simple. A single number/grade can not represent the sum total of an organization’s management of risk. These organizations employee from few to thousands. The jobs/responsibilities/parameters vary by orders of magnitude compared to those of a restaurant operation. Not restaurant-like at all.
  
  
• The public’s right to know? If my organization is private, I may want to share only so much information – and the public does not have a right to know all about my business, since my operations do not materially affect the public in any way, excepting emissions of hazardous substances above the RQ (the reason for the right-to-know law.)

Let’s recognize that safety is about people; in fact, safety is a people-oriented process. I contend it is not a compliance process (yes, complying with recognized safe practices is important, but that should not be the goal.) If staying in compliance were the goal of safety, then we would hire safety police and they would make people follow the rules. That simplistic approach, however, is exactly how many leaders, safety people, and especially the public thinks safety should be managed. It is simple, and it does not work. The advent of OSHA has reinforced this thinking. No blame intended, but OSHA is a rules-making/enforcing organization that has inadvertently provided the inaccurate perception that if you put in place the safety rules and regulations and get the workers to follow the rules, then injuries (accidents) will be avoided. Or, that management needs to provide a safe working environment, according to the safety regulations and that will eliminate injuries. Moreover, because of the threat of fines and negative publicity, organizational leaders also tend to focus on staying in compliance. Hence, the inordinate focus on being in compliance and getting the workers to follow the rules and numbers of incidents. Here, the problem is the safety pro’s inability to effectively communicate/educate/motivate/design systems and listen to workers and management with the goal of helping everyone become stakeholders and act like “owners of the business.”

Remember that Dan Petersen and I have emphasized that safety should be managed and measured similarly to the way the organization manages and measures its productive effectiveness – by the things you want to be done, not by the things you don’t want to be done (injuries.) What set of activities/actions is expected of each management person from the top to the bottom on a daily or periodic basis that supports risk reduction and great performance? The same for the hourly members. So, measure what you want people doing, not what you don’t want them doing! If leaders use statistics to measure effectiveness, they are fooling themselves. It is a program, not an integration of safety responsibilities/actions/accountabilities into the fabric of the organization.

Sorry for the long article – and pontificating.