Let’s talk about DE-incentivising businesses to properly manage Occupational Safety and Health (OSH), even at the most basic level. OSHA now requires businesses to report their injury and illness logs, which they will use to identify workplaces needing a compliance inspection. They are doing this due to their lack of adequate resources, and they want the businesses and industries to self-report their bad performance so that OSHA can “target” those businesses/industries. This is not my interpretation; this is precisely what OSHA stated in their need for this injury/illness data collection. If your business is still playing the “compliance games” with safety, then the business should be very concerned!
Is this really where we are in OSH data management in 2024?
Does anyone, for a second, believe that once a business/industry realizes what OSHA is doing with this data and the inspections and citations start piling up, these actions by OSHA will not consciously or subconsciously impact the data being reported to OSHA? We will see this in businesses doing the following, sometimes in genuine ignorance of what they are doing and, in some cases, knowing precisely what they are doing: Incentivizing employees NOT to report injuries and illnesses! (See my article last week story of “good intentions” with disastrous results for how this is done)
This injury/illness data analysis MUST be done at the facility level, which is one of the ONLY advantages to OSHA recordkeeping requirements. OSHA should hold businesses accountable for NOT doing these annual reviews of their injuries/illnesses AND generating action plans to address the trends identified in these annual reviews. Then, OSHA should hold those businesses accountable via citations for not doing these data reviews and taking the proper actions to reduce risks identified in these data reviews.
We need to shift to a proactive Safety Management System (SMS) approach and away from the reactive OSHA inspection/compliance approach. With that said, I have always supported OSHA’s Injury Illness Prevention Plans (I2P2) approach as it moves us toward a very simplified Safety Management System approach to OSH, much like the Process Safety Management standard (SIF model) did for catastrophic risks in the process industries. A 2010 proposal for an I2P2 rule included just six (6) elements of an SMS:
(emphasis by me) – pay particular attention to Element #6…
- Management Duties, including items such as:
- establishing an OSH policy,
- setting OSH goals,
- planning and allocating resources to implement and manage OSH, and
- assigning and communicating OSH roles and responsibilities
- Employee Participation, including items such as
- involving employees in establishing, maintaining, and evaluating the OSH SMS
- employee access to safety and health information and
- employee’s role(s) in incident investigations
- Hazard Identification and Assessment, including items such as:
- How hazards will be identified (e.g., information gathering, workplace inspections, incident investigations, hazards associated with changes in the workplace, emergency hazards,etc.)
- Hazard Assessment and Risk Prioritization, and
- Hazard Identification Methods and Tools
- Hazard Prevention and Control(s), including items such as:
- what hazards must be controlled,
- hazard control priorities, and
- the effectiveness of the controls
- Education and Training, including items such as:
- content of training,
- relationship to other OSHA training requirements, and
- periodic training
- Program Evaluation and Improvement, including items such as:
- monitoring performance,
- correcting SMS deficiencies and
- improving SMS performance
I dare any safety professional to say these six (6) elements are NOT a fundamental need within any business, regardless of the organization’s size or the complexity of its risks. OK, maybe we include a size threshold in requiring this I2P2 approach as I can’t envision a business with three employees pulling this off; but then again, maybe we require even this 3-employee business in certain High-Risk businesses to implement an I2P2. I’ll leave that up to the bureaucrats!
In the year 2024, it is time we move away from a bundle of individually written safety programs sitting in an untouched binder on shelves all around the workplace and towards the utilization of a basic SMS, which those written safety programs fit into as “controls” (see #4 above). This shift is relatively easy when senior leaders within the business want a valid SMS for the safety of their employees and contractors. It brings structure and a HIGHLY VISUAL safety effort that, once in place, is DRIVEN by the men and women who do the dangerous and dirty work! This simple approach will build TRUST and CREDIBILITY between management and their workforce, which is vital in any OSH/PSM effort.
This I2P2/SMS approach ends the “flash in the pan” or “program of the month” approaches to OSH, which many businesses are mired in today. It puts the FOCUS on the very visual SMS activities. And the beauty of all this? Implementing this 6-element SMS requires very little or NO CAPITAL expenditures! Instead, the money spent in the name of safety is on actual hazard abatements arising from the SMS activities such as Hazard ID, Incident Investigations, etc. Yes, this approach has a cost, as workers and management will be engaged in the SMS activities, which takes them out of their principal roles. But I can promise you that the relationships built during these activities and the culture developed via this approach will improve the other business elements (i.e., quality will improve, production will improve, losses will decline, etc.)
SAFTENG Members can read my nearly 400 articles on Safety Management Systems, where I lay out these basic SMS Models and how to implement and manage them (including how to measure them).
As always, I am available to discuss any questions you may have via email, text, or talk. I do not charge SAFTENG members for those emails, texts, or talks.
