Back to Basics is a weekly feature that highlights important but possibly overlooked information that any EHS professional should know. This week, we examine how to leverage your safety culture to control hazards.
Are you concerned with your company’s recordable injury rate or your workers’ compensation experience modification (Xmod) rate? You may want to look at your company’s safety culture, especially compliance with safety rules in your facility or at jobsites. It may also be worth developing and implementing a company workplace safety and health management system.
While it’s important to keep an eye on your outcomes—the recordable injury or Xmod rates—you also need to pay attention to the underlying hazards, risks, and risky behaviors that lead to accidents.
The most obvious sign of a troubled safety culture is workers’ failing to comply with your safety rules, policies, and procedures. Worse than mere disregard for rules is outright risky worker behavior.
Safety rules compliance
Employees’ “bending” or breaking your workplace safety rules and procedures can lead to serious injuries.
For example, a Walmart distribution center found itself confronting employee noncompliance along with a lockout/tagout citation following a serious worker injury. Walmart contested the Occupational Safety and Health Administration (OSHA) citation before the Occupational Safety and Health Review Commission. The company learned that both company and contract employees regularly circumvented company procedures for entering an electrified monorail system (EMS) at the warehouse. The system consists of trolleys to move pallets of merchandise within the warehouse. Employees of Walmart and its contractor, Swisslog Logistics, crossed over fixed conveyors to enter the EMS. Employees also placed pieces of cardboard over the light curtains between loops of the EMS (a light curtain’s being tripped normally would stop the trolleys in that section), leaving the light curtains in a muted state. Employees could walk from one loop to another without tripping a light curtain, even where trolleys operated in full-speed mode. An employee who was servicing trolleys was struck by one, and a piece of machinery penetrated his leg.
Rank-and-file employees aren’t the only challenges to your safety culture, and the threat can be hard to spot if the source of the threat is one of your managers and supervisors. A recent research study found that abusive behavior among managers and supervisors eroded safety behavior, leading to poor worker safety outcomes.
Bully bosses can make workers become more self-centered, causing them to forget to comply with safety rules or ignore opportunities to promote others’ safer work behaviors. It can even create a situation in which other workers are more likely to become injured.
Researchers suggest intervening and using training programs to improve managers’ and supervisors’ skills in interacting with the employees they supervise so they have the skills to provide discipline and feedback in ways that aren’t offensive or threatening. Researchers also recommend promoting a civil and engaged working environment, strengthening social bonds among employees to create a buffer that limits the negative consequences of their boss’s disruptive behaviors. You may even want to institute a transparent performance evaluation process so employees have no questions about their social status in the workplace.
You need to ensure “safety first” is more than a motto and that all your managers and supervisors are steeped in your company’s safety culture.
A strong safety culture enhanced with emerging safety technologies may yield even better results. Researchers found that trucking companies that have strong safety cultures and take advantage of advanced safety technology have seen better safety outcomes than motor carriers that don’t.
Best practices in a strong trucking safety culture require consistency that includes:
- Having zero-tolerance policies for hours-of-service violations;
- Implementing improvements in hiring policies and training protocols and modifying driver scheduling to reduce fatigue;
- Informing drivers about the carrier’s safety culture during orientation and including all employees—not just drivers—in safety training and education; and
- Sharing carrier-wide safety indicators with managers and drivers.
Training, safety, and health management programs
Training can be critical. Researchers have found strong evidence that training affects worker safety and health behavior, especially behavior surrounding ergonomic hazards.
Training needs to be geared toward the intended audience, and you need to consider your employees’ cultural and educational backgrounds and literacy levels. Training may also need to be delivered in a language other than English.
The American Society of Safety Professionals (ASSP) has suggested looking at safety training at a higher level, integrating training into an overall safety and health management system. Safety and health management programs include safety observations (“walking around”), safety audits, job hazard analyses, and incident investigations.
The elements of a robust safety and health management system can help reinforce a strong safety culture in your facility or at your jobsites.
‘Hidden’ safety culture
You also need to be aware of a potentially “hidden” safety culture, like the one at the Walmart distribution center. This hidden safety culture may be starkly different from your stated policies and procedures and may not reflect the policies and rules in the manual sitting on your safety manager’s desk.
First, you’ll need to embrace a certain level of discomfort. Issues with your safety culture may not be obvious, so you’ll need to be persistent until you get to the underlying issues at your jobsites or facility.
Then you need to look below the surface for hidden “mixed” messages, picking up on the internal forces that can lead to unsafe actions. Develop consistent messaging that reinforces how workers should perform their duties safely.
Also, develop your pattern recognition skills. Look for common threads in incident investigation reports, and look for employees’ jury-rigged solutions; what works for their ease and comfort may pose a safety hazard.
Your facility’s current equipment may pose hazards that a replacement might eliminate.
Continue asking the right questions, but know you may need outside help.
Safety culture in a multigenerational workplace
While there are challenges to fostering a strong safety culture in a multigenerational workplace, older workers who remain in the workforce can offer a model of safe workplace behaviors that younger workers can emulate. Even though their injuries may be more severe when they do become injured, older workers tend to become injured less often, and they may know of hazards in the workplace that they picked up over years of experience.
Your safety culture also may need to adjust to cultural differences in an increasingly diverse workforce. Consider your own biases, as some workers may not have grown with the same cultural messages as you and other employees, and don’t let your assumptions hinder your safety efforts.
For example, you and some of your employees may perfectly understand American sports metaphors like “team” and “teamwork,” but workers from other cultures may be more accustomed to family metaphors when referring to work colleagues.
Check your assumptions so your safety policies and procedures don’t get “lost in translation.”
Safety and health management guidance, standards
A strong safety culture may benefit from a professional safety and health management system.
OSHA support for safety and health management programs has long been a part of the agency’s Voluntary Protection Program (VPP). The agency’s 1989 voluntary safety and health management program guidelines were revised in 2016.
The 2016 guidelines stress worker participation more heavily than the 1989 guidelines. The agency suggests that employers encourage workers to report safety and health concerns to management, fully participate in planning and implementing their safety and health management program, and give workers unrestricted access to safety and health information.
There also are industry consensus standards for safety and health management programs.
The ASSP updated its industry standard for safety and health management programs (Occupational Safety and Health (OSH) Management, American National Standards Institute (ANSI)/ASSP Z10) in 2012.
One of the keystones of a Z10-conforming occupational safety and health management program is “buy-in” from managers, supervisors, and frontline workers.
While elements of the Z10 standard are similar to OSHA’s voluntary guidelines, the Z10 standard includes provisions for internal audits and management review.
While also an international safety and health standard, the Z10 standard isn’t interchangeable with the international standard (International Organization for Standardization (ISO) 45001-2018).
ISO 45001 is an international consensus standard for workplace safety and health management programs that uses a “plan-do-check-act” methodology. Some corporations have contract requirements for ISO 45001 and other standards, insisting that vendors or contractors implement ISO 45001 programs, ISO 9001 quality management systems, and ISO 14001 for environmental management systems.
Much of ISO 45001 was based on the earlier British standard Occupational Health and Safety Assessment Series (OHSAS) 18001. The British Standards Institute (BSI) canceled OHSAS 18001 with the adoption of ISO 45001.
An ISO 45001-conforming safety and health management system includes employer commitment and worker participation, hazard identification and controls, and training. The ISO 45001 standard, however, also includes provisions for monitoring and measurement, management review, and system improvement.
California’s IIPP standard
While federal OSHA doesn’t require employers to establish safety and health management programs, the California Division of Occupational Safety and Health (Cal/OSHA) enforces a state injury and illness prevention program (IIPP) standard.
Under California regulations, every employer in the state must establish, implement, and maintain a written IIPP. The general industry IIPP standard is often the most frequently cited California standard, followed by the heat illness prevention standard and the construction industry IIPP standard.
Employers must designate a manager to be responsible for the IIPP. Like OSHA’s voluntary guidelines, California’s mandatory IIPP includes requirements for identifying and controlling hazards and providing worker safety education and training.
The IIPP also contains recordkeeping requirements for employee training and scheduled and periodic workplace inspections, much like the internal audit requirements of international standards. An IIPP also must cover the employer’s procedures for investigating employee injuries and illnesses.
The California Division of Occupational Safety and Health (Cal/OSHA) does offer a sample model IIPP employers can use when developing their own program. However, the agency cautions employers that the model program isn’t an “OSHA-proof” boilerplate. The written program regulations also require employers to adopt certain practices like providing employee training and conducting regular inspections to identify unsafe conditions and work practices.
The manager or supervisor with authority and responsibility for the IIPP should recognize employees who comply with safe work practices, discipline employees for noncompliance, communicate hazards, train employees in safety and health procedures, and investigate incidents and correct hazards.