Safety Culture Development - Identify and Implement Controls

The next step in Positive Safety Culture development for an Organization after determining its Risk Tolerance, is implementation of controls for identified risks and hazards. Controls may be based on regulatory requirements or industry practices. Industry practices may be found in Consensus Standards proposed by professional organizations like the American National Standards Institute (ANSI), American Society of Mechanical Engineers (ASME) or International Standards Organization (ISO) to name a few.  

In the US, OSHA is the Federal regulatory agency that has enforcement authority (or States in State Plan states) for Occupational Safety and Health. Regulations may prescribe the hazard control measure or the framework for establishing controls; remember, there is a risk of legal penalties for non-compliance as well as negative publicity (becoming more common). Keep in mind that OSHA provides compliance assistance; resources available on the OSHA website (Or State Plan websites) are very good at assisting business and safety leaders in determining what regulations apply to the Organization’s operations. For organizations in a state where the State Department of Labor has regulatory authority vs. OSHA, State Plan web resources are available for the search effort; I have found them very useful in furthering the organization’s goal of safety program development.

Industry practices may be determined by researching Consensus Standards; I have found that the Internet is a good source of information in this area. Also, OSHA and State Plan regulations may incorporate Consensus Standards by reference in their regulations. One downside of obtaining Consensus Standards is that trade groups will charge for their standards and possibly membership in the trade group to access them. However, when organization leaders join with these trade groups, networking can become an excellent source of information and professional development, making the task of identifying risk/hazard and controls easier. Industry practices usually don’t carry the penalty of non-compliance risk; the upside is that adopting industry best practices generally will ensure that the Organization is well within regulatory compliance.  

Safety professionals have established a hierarchy of risk and hazard control that has withstood the test of time and practice: 

Elimination of the risk/hazard. It is worth consideration even though eliminating the risk/hazard may not be practical. An organization in the Southeast US will not be able to avoid hurricanes. It may not be possible to operate a chemical plant without performing hazardous Permit Required Confined Space Entries. Those situations require implementation of appropriate risk control measures.  Using a common carrier vs. owned fleet eliminates the risk of motor vehicle incidents. Use of an aqueous based cleaner vs. flammable or combustible solvents for cleaning, substantially reduces risk of fire and occupational exposure to hazardous chemicals. In those situations, risk/hazard elimination may make good business sense, depending on client demands.  

Elimination of the risk/hazard may include transferring the risk of high risk/hazard tasks to another organization that has control resources and is optimized to perform the task profitably. When properly utilized, with appropriate contractor qualification procedures, risk transfer has the advantage of allowing an organization to focus business and safety resources on core operations and mission. Operations Risk Transfer works best for organizations that infrequently perform or do not wish to allocate resources to self-performing high risk tasks.  

Substitution of less hazardous material or task techniques is the next best solution to controlling risk/hazards. One of the above situations, substituting less hazardous chemicals, is one example. Another would be to limit work at elevation using ladders to only those tasks where a ladder is absolutely required due to the work being inaccessible to an aerial lift or scaffolding; or is of short duration limiting an employee’s time exposure to the risk/hazard. Performing internal inspections using remote technology or cleaning of a Confined Space from outside the space, reduces the risk to personnel.  

One way to approach substitution is to challenge the thinking “We’ve always done it this way, why change?” Changing the thought process to one of “How can we do this task safer and more efficiently?” results in a better way of completing the task. The resources required to execute a proper Permit Required Confined Space Entry are considerable. Reducing the personal protective equipment and fire protection requirements necessary to clean parts with a flammable or combustible solvent, by substituting a less hazardous aqueous based cleaner saves money in the long term (Not to mention reduction of environmental management requirements for the spent cleaner!).  

Implementation of engineering controls. Designing for Safety and engineering out the risk/hazard has real value in a risk/hazard control program. Simply put, engineering controls place a barrier between the hazard/risk and the person to prevent injury or allow safe work practices to be implemented easily. It is most effective when equipment design and installation or building design or retrofit is performed. Machine guards, fixed fire detection/suppression systems, lockable electrical disconnects and valves, and ventilation to remove air contaminants are common examples of engineering controls. Engineering controls have the advantage of minimizing human execution of risk/hazard controls.   

Lockable electric disconnect switches and valves enable employees to easily implement lockout/tagout; even better is grouping lockout points as close to an operator station to encourage compliance with the energy control procedure. Ventilation to control generation of toxic air contaminants reduces the need for employees to wear respirators (Not a popular thing to do!).  

An organization that adopts the value that we will implement a management of change program that performs a thorough safety engineering evaluation of our operations, and commit resources to designing out hazards wherever practical, demonstrates that they are committed to developing a positive safety culture.  

Administrative control (policy and procedures). Administrative controls to reduce risk/hazard are next in line. Here’s where most people think the safety program begins; but remember that there are 3 levels above this one for risk/hazard control! This is where safety documentation becomes important; the job is not complete until the paperwork is done! It may be a Safety Management System that establishes a framework for how the organization’s safety requirements will be administered, and audited for implementation and effectiveness. Or could be a Safety Program that is a written manual of safe work procedures to follow to achieve compliance with organization requirements. For organizations with few identified risks; it may be as simple as a few compliance procedures and a collection of Job Safety Analysis for tasks performed. Safety Management Systems work best for Organizations with multiple locations or complex compliance requirements; safe work procedures must still be established.

The issue with administrative control is twofold: One is the control must be administered by organization personnel (employees must perform Lockout/Tagout for hazard control, someone has to review Permits to Work like Confined Space Entry Permits, production planners may have to take in to account how much hazardous material goes through a process to control employee exposure, etc.). This requires properly informed personnel resources to implement; not always compatible with today’s lean philosophy of organization staffing. The second is that people are, well, human, and make mistakes! Human error, in combination with a failure of rigorous engineering evaluations of process has resulted in some of the worst industrial incidents in history. Another point to keep in mind; the more complex administrative controls are, the greater the probability that errors will happen in implementation of the control measure.

Included in administrative controls is safety training for employees. Organizations should consider a high quality training program. It is a serious error in creating a Positive Safety Culture to be stingy with resources in this area as it is a highly visible program element to employees. All organizations will need to conduct training. It is required for regulatory compliance controls like Emergency Action Plans. There is also a need to clearly communicate safety program goals as determined by the organization’s selected control strategies (safe work practices) and Risk Tolerance. Consider this: If an organization determines they have Permit Required Confined Spaces on site and do not allow employees to enter them (established by Risk Tolerance), the organization must have an effective communication program so that all employees understand that (selected hazard control). 

Personal protective equipment (PPE). This is the least effective risk/hazard control; yet may be unavoidable in many identified situations. The issue with PPE is that it requires people to consciously use it! Also, PPE must be properly selected to be effective in controlling the hazard; this usually requires effective risk/hazard evaluation (type, severity of exposure), resource allocation (purchased in enough quantity to be readily available, distribution), training in use, inspection to ensure effectiveness (not damaged or broken), properly sized (safety shoes, gloves or body wear), and, most importantly, used! Again, it requires organization personnel to administer PPE programs to ensure compliance and the more complex an organization’s PPE program is, the greater the non-compliance rates may be. PPE requirements must be clearly communicated. Since it will be an individual employee’s responsibility to use PPE, trial of PPE required and selection by affected employees is critical to acceptance of a PPE program. Again, engagement of the workforce in this process is crucial to building a Positive Safety Culture.  

Engaging employee participation in design of control measures from the personnel who actually will be performing the work has the following advantage; they will know if the control strategy is practical, they may suggest even better controls! Nothing discourages participation in a safety program for employees trying to perform a task quite like being issued safe work procedures that are difficult or complex to follow. Command and control risk/hazard control strategies, as in follow the established procedure or be subject to disciplinary action, may work, but may actually result in non-compliance. 

As engagement and input from employees increases in establishing safe work practices, the WHY as well as the HOW of becomes clear to them. People find it psychologically difficult not to comply with controls they helped develop and encourages employee participation in consistently performing the selected control. This is crucial to establishing a positive safety culture. In short, the Safety Program is a DO, not DON’T program, with positive outcome for everyone.