After 25 years of being in the industrial safety profession, I have heard the debate about “culture” to the point it has become ridiculous. I was very fortunate to work for two of the finest plant managers early in my career and both of these men were strong leaders and the safety of those in their plant was without a doubt their #1 concern. And both of these men would tell me virtually the same thing when it came down to culture vs. compliance and you know what, they were both so right.
Can we say we have a good “safety culture” if we are not meeting the bare bones minimum OSHA requirements that have been around since 1972?
We can not fool ourselves by thinking that mere compliance is an indicator of a good safety culture; however, without a high degree of compliance with the OSHA minimums, we can not honestly say our safety culture is good.
OSHA compliance is the building block of a developing a “safety culture”. Having a written safety program based on OSHA requirements and then NOT following these programs will ensure we never have a good safety culture. I see it all the time and at great cost the business’s bottom line and to work safety… a facility will sort of gloss over basic compliance and opt for the fancy behavior-based safety, lean safety, or whatever the flavor of the month is at the time.
These fancy and often costly safety endeavors often blind management to what is really happening in their facility. I saw this happen at my first plant. The plant manager fought corporate to the very end in his attempt to delay the implementation of a behavior based safety process. He knew we were not ready after spending the last six years with actual safety professionals managing the safety process and learning just how far out of line the written programs, training, and practices were from being safe. We wanted to focus on the safety basics (he liked to call it “blocking and tackling”) before we tried something fancier like BBSP. His belief was that there is a lot of good in meeting OSHA compliance and once we have milked OSHA for all they have to offer, then we would begin to look elsewhere for continuous improvement. But he firmly believed that OSHA standards had a lot to offer when they were fully understood, implemented, and managed within an all-encompassing safety management system. Claude was so right and he taught me so much about OSHA compliance and how to use OSHA as the foundation upon which to build a world-class safety culture.
Today I receive multiple inquiries about ideas of “leading indicators” a business can measure rather than merely measuring injury frequencies and severities. And still to this day I provide them with ideas as to how to measure their OSHA compliance programs as a baseline measurement. This I learned from my second plant manager, a man that probably measured the toothpaste consumption in his house! My first day on the job granted this was in 1995, was to bring him the ten (10) safety measurements we were going to measure that year. Of course, I had OSHA rates, WC $, etc. but in 1995 the idea of “leading indicators” was really cutting edge. I called every safety professional I knew, even called some of my old professors at Murray State hoping maybe I had missed something important. A few days later I went back to Dale fearing the worst; it was, of course, a “challenge” and “teaching moment” for him. He knew what I was taught in school and in my limited experience as he saw it for years during his time at Monsanto. But in the late 1980’s Monsanto began focusing their safety measurements on “leading indicators” and man oh man did he have a bag of goodies for me.
He asked me what were some of the compliance matters that I grew frustrated with in my short career. Having just battled my last management group over “respiratory protection matters” I began to rattle off the same frustrations most safety pros would say:
1) workers not getting their fit test
2) workers not showing up for their training
3) workers not doing their medical evals
And these were ANNUAL battles that a safety pro will NEVER WIN on their own. So Dale brings these frustrations back to OSHA compliance, as all of these are basic OSHA matters in any respiratory protection program. And as Dale pointed out, in a chemical process, respiratory protection can be a life and death situation. He asked me… ” should we measure these three requirements and then I can hold management accountable???”. After I picked myself up off the floor from shock, I said heck yeah. And so it began, I learned how to manage “safety” using my OSHA compliance program requirements. Dale then would hold those managers who failed to meet these requirements accountable and rewarded those who met the safety expectations. We eventually revised our safety incentive program from OSHA Rate based to Safety Actions based. We saw a 50% reduction in injuries the first and second year; all the while INCREASING our 1st aid and near-miss reporting by 100%. Our injury severity rate was reduced by 900% as well. All of this was achieved by merely meeting the OSHA requirements and MANAGING our safety programs, which were written based on OSHA requirements. It is amazing what can be achieved when workers show up to training (and have to pass tests) and managers are doing periodic inspections and audits of their work areas and workers.
