I am sure we could debate this topic all day, but it is a topic that “I do not play well with others” on. The idea is that if we shorten our written compliance programs or SMS elemental programs, it will cause more people to read them and use them more often. I say hogwash to this idea, and I believe in detailed written safety compliance and management programs. And I have seen firsthand what happens when a company gets it into its head that a shorter safety program will somehow result in better compliance/conformance from the workforce.
I have lived this with a few former clients. I was pulled into a lawsuit when a facility safety person threw me under the bus after they had downloaded my Hot Work Program, Permit, and Audit Form, a total of 37 pages; they then reduced the entire program down to 7 pages, basically removing all the critical elements from the program. An accident occurred, and lawsuits were filed, and the business lawyers looked to lessen its liability by blaming me and SAFTENG for a faulty HW program. That lawsuit cost me over $2,000 in legal bills, made SAFTENG.net become an LLC, and have an insurance policy (hence we now charge for memberships to pay for the insurance and lawsuits!)
The first thing to consider in this debate is that very few people will read a safety program from cover to cover during their entire career. And our programs should be organized such that a person would never need to read an entire safety program. However, our written programs should cover every aspect of what is expected from the program.
Secondly, our written programs MUST be more than simply regurgitating the regulatory standard language. The program(s) needs to explain WHY we are asking for the activities and documentation, and they should never be written to “just comply” with the government agency. These programs are intended to be the framework of our complaince efforts which are the cornerstone of my organization’s safety efforts. Cutting corners in these programs will NEVER result in better/more consistent behaviors as necessary to comply with the program requirements.
Lastly, 100% of these shortened programs I have audited had serious fundamental complaince issues. Many written safety programs are intended to provide structure for safety controls/safeguards that are not simple to implement and manage. We can play games with font size, line spacing, and margins of the program (yes, I have seen all done to reduce the number of pages in the program to meet a company directive!); but these are true games being played with safety.
Don’t fear a well-written safety program – embrace the details! But these programs must follow a regimented format so they are EASY to navigate and find the information the program is intended to convey. We should never have complaince programs or an SMS that forces anyone to read the program from cover to cover to find what they are looking for.
