Besides cost-benefit, another issue that is often raised is whether mandated compliance, through threat of citation and/or poorly conceived requirements, actually diminishes levels of safety. Dan Petersen, a well-regarded safety professional wrote, “Most organizations I am familiar with have come to believe that, when it comes to safety and health, they have two distinct concerns, which seem to have little to do with each other: preventing accidents and regulatory compliance.”
Based on my experience, both as a safety director and a risk management consultant, I am of the opinion that requiring safety management programs is not an either/or dilemma of compliance or safety, and that effective safety management does reduce injuries and associated costs. The fundamental issue has been one of translation — which is to say that the companies that struggle with safety management (as opposed to those that reject the requirements out of hand) are simply unable to translate safety requirements into manageable and sustainable day-to-day policies and procedures, and they ultimately give up. This is an issue Cal-OSHA has addressed but not overcome.
On July 15, 2011, John Howard, Cal-OSHA Chief, gave a presentation entitled Injury and Illness Prevention Program: The California Experience, in Washington D.C. to the Small Business Roundtable. He summarized the pitfalls encountered rolling out the requirement and Cal-OSHA’s efforts at supporting implementation (translation). I have not found the transcript of the presentation, but the supporting PowerPoint provides a good overview of the specific topics he touched on.
Early criticisms of SB 198 were that it was “overly broad and burdensome” and that many employers lacked the expertise to develop (translate) requirements into an effective program. Within three years of enactment, the legislature had modified some requirements and Cal-OSHA had produced several model programs (translations) that could be used by a variety of businesses. The programs were followed with the introduction of compliance checklists (translations) that were intended to guide users to the regulatory top of the mountain. However, and as Howard notes, the downside of these support tools was that they often resulted in “paper compliance” that did nothing to enhance actual safety management. What he did not note is that they also did not provide effective compliance translation.
Currently Cal-OSHA Consultation provides on-site assistance and has developed a variety of eTools, including an online IIPP “wizard” to support companies with the development and implementation of their Injury and Illness Prevention Program. Unfortunately, many companies are leery of requesting on-site help, and it is not at all clear whether the web-enabled support helps companies struggling with the core issue of day-to-day management of their safety program.
I do not believe that it does, and would offer the following suggestions to those who have struggled with IIPP implementation:
- Cal-OSHA starts with the written program. You should not (but do keep your old program intact while you build the new one).
- Do start with the supervisors who oversee the productive part of whatever you do.
- Introduce a weekly or bi-monthly form that documents day-to-day behavior reinforcement. A month later add a weekly safety assessment/fix to the mix, the next month add weekly group meetings, all on the same form. Provide training and define expectations as each new component is added. To effectively support these required activities create forms that must be filled out completely in a given time frame. The frequency of completing a form can be adjusted depending on risks inherent in a work area, but the form should always be designed to be filled out completely in any given cycle.
Learn about performance support and job aids, and develop multi-level performance support forms to guide and document your program.
A simple checklist-style form that includes only basic details can guide and capture essential activities — including behavior reinforcement, safety assessment/fix, and tailgate training. Keep each form to a single page. Also, consider desktop/smart phone/tablet applications as alternatives to paper forms.
- This approach is completely scalable. Delegate to all departments and levels — design interlocking performance support forms that culminate in a monthly Safety Activity Report submitted by the safety manager to the owner/CEO. If supervisors are required to engage in behavior support conversations, then the department manager’s monthly form should include confirmation that the supervisors are fulfilling the required behavioral support activities and an assessment of the quality of their work, and so on.
- Look to the Injury and Illness Prevention Program requirements for those activities that should at some point be integrated into the Safety Performance Support Forms — likely activities include either doing, assessing, or assuring the doing of: behavior enforcement and reinforcement; training (new employee, new hazard, tailgate, etc.); inspection; day-to-day hazard identification and correction; accident investigation; employee suggestions, and so on.
- Incorporate other compliance areas (HazCom, Heat Illness Prevention, Lockout/Tagout) into your performance support forms as training, inspection, and behavior reinforcement activities.
- Six months after you start this process consider rewriting your IIPP to reflect what you are actually doing.