Draft Strategic O.H.S. Management Plan-For discussion purposes with the executive team
A Introduction
? are currently doing a number of good things in safety but the Safety Management System has a number of gaps in comparison with “ best-practice safety”. The suggested Strategic O.H.S. Management Plan is focused on developing “best-practice safety” as the organisation expands.
B Objectives of the Strategic O.H.S. Management Plan (sourced from force-field analysis discussions)
Keep workers safe
Reduce lost time
Save money
Escape enforcement action
Reduce human cost of accidents
Make a more attractive place to work
Comment
It must be realised that compliance with O.H.S. legislation is a minimalist approach in O.H.S., to achieve “ best-practice safety” one must substantially exceed the requirements of legislation. “Best- practice safety” makes common law claims more defensible.
C Safety Quotable Quotes
1 “Are my safety actions defensible in court?”
2 “If you keep doing what you are doing now, you will continue to get the results you are getting now”
3 When initiating change remember “People support what they create”
4 "A health & safety problem can be described by statistics but cannot be understood by statistics. It can only be understood by knowing and feeling the pain, anguish, and depression and shattered hopes of the victim and of wives, husbands, parents, children, grandparents and friends, and the hope, struggle and triumph of recovery and rehabilitation in a world often unsympathetic, ignorant, unfriendly and unsupportive, only those with close experience of life altering personal damage have this understanding"
D Zero-Harm Principles
It is recommended a set of Zero-Harm principles be developed , promoted in company literature and explained to employees eg.
“The safety of our people is a value that is not compromised
Safety excellence is recognised as good business
Leaders at all levels are safety role models
Effective safety leadership is a pre-requisite for promotion
People are aware of the hazards and risks of their employment and act accordingly
Compliance with safety standards and procedures is absolute
At risk behaviours are not acceptable and addressed when observed”
E Top priority items
1 Compliance with legislation
Debbie and I have already noted some areas of non-compliance. Audits from the Division of Workplace Health & Safety will reveal gaps in compliance with statute law, these gaps must be filled
2 Manual handling accidents
The most frequent and severe accidents in the last 5 years are manual handling ones. ? should contact other companies doing similar work to discover if others have appropriate solutions. It may be appropriate to visit other companies if solutions are out there. A trial program with limited scope should be initiated to review manual handling tasks, assess risk and recommend improvements where necessary. Should the trial be successful the scope of work will be expanded. This program will be conducted by an ergonomist or O/T. It may be appropriate to form a small project team to oversee the required work
3 Nail gun accidents
Nail gun accidents appear to be the second most frequent and severe accidents in the last 5 years. ? should contact other companies doing similar work to discover if others have appropriate solutions. It may be appropriate to visit other companies if solutions are out there. It may be appropriate to form a small project team to oversee the required work.
4 Class 1 personal damage
A method of classifying personal damage that seems appropriate is the following-
CLASS 1-Damage that permanently alters a persons life e.g. death, paraplegia, amputation of a leg, severe psychological damage.
CLASS 2- Damage that temporarily alters a person’s life e.g. fractured leg that repairs with no lasting impediment, deep laceration that has no underlying tissue damage and repairs without significant scarring
CLASS 3 does not alter a person’s life
The report of the Industry Commission 1995 indicates that safety in Australia is fundamentally a class 1 problem (13% of occurrences were class 1 with 82% of cost.) Most safety management systems in Australian industry focus on lost time accidents within the organisation. Better returns for effort will be gained by focusing on Class 1 damage in the companies industry or Australia-wide. Attempts must be made to identify Class 1 personal damage elsewhere that is relevant to the particular organisation.
F Must Dos
1 Executive team safety briefing
The executive team should receive a briefing on safety due diligence and safety responsibility of managers by a legal professional experienced in safety statute and common law.
2 Induction training
Review current approach with the view to reducing the information overload and incorporating modern adult learning principles. There needs to be a separate induction for inside and outside employees. Any training must be interactive using a variety of visual aids and case studies, discussions, exercises etc. Need to look critically at the time between employment and attending the induction. Computer-aided solutions for induction training can be cost efficient and should be aimed for.
3 Performance appraisal
Performance appraisals of all staff must have a section asking what actions have been carried out to promote safety. The emphasis should be on solutions not what accidents have occurred. There needs to be detailed safety responsibilities / accountabilities on job descriptions.
4 Hazard identification / Risk assessment / Hazard control
Supervisors / managers and those in high risk occupations should attend a 3 hour practical course on the above subjects. The principles should then be put in practice in the workplace.
5 Emergency response plans
Plans to be reviewed and practiced. There are some gaps in compliance with fire safety legislation at the moment.
6 Contractor safety
All aspects of contractor safety to be reviewed.
7 Job Safety Analysis
A core of supervisors and selected workers from high risk areas to attend an approx 3 hour workshop on Job Safety Analysis with the view of developing Work Method Statements. Work Method Statements must, as a minimum, be developed for all high risk tasks
8 Supervisor / manager safety training
Supervisors and managers should attend a 1 day workshop or 2 half day workshops (alternately these could be covered in a series of 1.5 hour workshops) to cover the following topics-
Statutory obligations under the Workplace Health & Safety Act
Common law principles
Safety leadership
How to conduct a safety meeting
Accident investigation
9 Safety meetings
Moves have begun to introduce regular tool-box meetings
Supervisors need basic training in the conduct of these meetings and the safety department can assist and / or supply resource materials.
10 Audits
The companies that are really good at safety have an internal compliance and systems audit about half way through the year and an audit by an external accreditation authority annually.? need to consider if you want to have your Safety Management System accredited to A.S./N.Z.S. 4801 “Safety Management Systems. My recommendation is to aim for 4801 accreditation by the end of 2009
Many large firms would demand such accreditation of their contractors and some firms use the accreditation as a marketing tool. I would imagine your current safety approach needs a fair bit of work to meet the 4801 requirements.
11 Employee training
As a minimum employees need to be trained in the statutory aspects relevant to their particular work.
12 Safety reps / Safety committees
Members need to be trained in their roles and responsibilities, there are several training providers who can provide this training. Safety committees must not replace the normal process of management resolving safety issues. If you are not careful safety matters are saved up until the next meeting instead of being addressed straight away by management. Safety committee meetings need to be livened up with a bit of training and problem-solving activities .Giving the committee something meaningful to do instead of whingeing is always a good idea.
13 Forklifts
The Victorian Workcover authority has innovative forklift safety programs, these need to be examined for their relevance to ?
14 Fleet
Q.U.T. have innovative fleet operating and fleet safety programs that need to be examined for their relevance to ?
15 Traffic management plans
These need to be developed for the site.
16 Screen-based equipment
Training / information be given on safety aspects of screen-based equipment
17 Pre-employment medicals
Employing someone without a pre-employment medical is like buying a car without a roadworthy certificate. If you do not have audiometric tests when an employee starts with you how can you defend a common law claim that a person acquired noise-induced hearing loss in your employment. As a minimum all people in outdoor occupations should be examined. Drug & alcohol screening would be part of the medical.
18 Safety slogan
Foster a competition for employees and their families to develop a safety slogan for ? new direction in safety, modest safety-related prize. Some slogans I have seen are “Safety first-production will follow”, “Zero for life”, “If it is not safe do not do it” and so on.
19 Safety training needs analysis
A safety training needs analysis should guide the conduct of safety training.
20 Monthly Safety Report
A monthly safety report should be developed to regularly report on the status of safety.
21 Hazardous substances
? do not have many hazardous substances but there are gaps in compliance with legislation that need to be filled.
22 Safety inspections
There is a need to introduce a system of at least monthly checks of the workplace by the supervisor using a targeted safety inspection checklist
23 Safety communications
Develop a monthly one to two page Safety Newsletter to go to all employees notifying them of relevant safety topics. . Encourage face-to-face communications from the supervisor on safety matters relevant to the workplace.
24 Safety record-keeping
Safety record-keeping in a central place needs consideration. Current filing system in the safety office is incomplete.
25 Industry approaches to O.H.S.
? should promote industry approaches to safety
26 Nominated medical advisors
Establish a relationship with a small number of local doctors, have them meet the senior management team, tour the workplace so they can understand the demands of the work, show them what alternate duties are possible, take them out to dinner and pour some grog into them. The supervisor should accompany the employee to the doctors to explain what alternate duties are possible.
This will do nothing to prevent accidents but will give you some element of control over the length of time off work the doctors will give. You cannot insist an employee goes to a particular doctor but most employees will be happy to go to a company nominated doctor.
27 Safety noticeboards
Safety noticeboards should be established in major work areas to display things like accident alerts, safety committee meeting minutes, tool-box meeting minutes , safety statistics. Etc.
28 Role of the OHS Professional
The OHS professional should be an adviser to management not the doer of the Safety Management System. For safety to be successful line management line management must drive it.
29 Electrical safety
A few items have escaped the test & tag program and a program of testing earth-leakage protection needs to be initiated. Requirements of electrical safety legislation need to be examined and compared with current practice.
30 Celebrate success in safety
Celebrate success in safety. If an employee comes up with a good safety idea or a section goes a long time without accidents have a bar-b-q and appropriate photos and a short storey in the safety newsletter
31 Executive team to undergo training in safety leadership
Leadership is the often forgotten key to success in safety, the executive team need training in this area.
32 Safety documentation
A lot of the existing safety documentation is so detailed and ponderous it would take someone much more dedicated than me to sit down and read it. You cannot seriously expect the average employee to read some of this material.
Could dos
1 Well-being program
Research well-being programs and introduce a targeted, cost-effective program
2 Intranet
I have not really come to grips with ? computer systems as yet but would comment that many companies put all their safety related information on an intranet site.
3 Take 5 / S.T.O.P.
You will recall the man from Cemex showed their Take 5 booklet, there are a range of these tools designed to encourage employees to think more about the hazards of their work.
4 Safety champions
Some companies ask for nominations from the workforce for “Safety Champions” to influence front-line workers. Often a “Safety Champion” is selected from the senior management team.
5 Quality Assurance
I have seen Quality Assurance programs add much rigour and efficiencies to management systems, including safety. The continuous improvement philosophy that goes with Q.A. is important. Something worth thinking about as the company expands.
6 Safety specifications in job ads
The really successful companies in safety put safety messages and stipulations in job advertisements
7 Off the job safety promotions
The companies that are really successful in safety have off the job safety promotions
8 Discounted safety items for sale to employees
It is often possible to arrange with your suppliers for discounted sales of safety-related items such as fire extinguishers and first-aid kits to your employees.
Comments on the draft Strategic OHS Management Plan
Most of the recommendations above are pretty standard approaches in companies I have worked for previously. Some of it will require explanation as to the need and process. You will have your ideas on the recommendations and you will have your own ideas for inclusion in the plan. It is suggested the executive team discuss the draft plan and develop a version they are happy with. This version to be discussed with the safety committees and a cross-section of supervisors and workers for input. Dates for completion, responsible persons and , where considered necessary, costs, need to be assigned
The final Strategic O.H.S. Plan to be communicated to all and used as the basis for Operational O.H.S. Plans for each major department. These plans to describe the nuts & bolts of how the Strategic O.H.S. Plan will be implemented. Once plans are developed progress towards the deliverables must be regularly reviewed.
Some outside assistance will be needed for some of this work but the majority is within the capacity of the existing safety team.
I would imagine it will take at least a year to implement the recommendations above.
Background Reading
SAFETY BENCHMARKING
Over a 14 month period in 1994 -5 BHP Minerals carried out an extensive international safety benchmarking exercise with “best in safety class” companies throughout the world. Cost approx. $25 Million.
25 locations throughout the world participated in the study. An approximate 100 page report on findings is available should anyone wish to refer to it.
The following were recurring themes in the world’s best safety performers.
1. Executive management provides the impetus for safety performance. This means that senior management is not only committed to and supports safety, but that it insists on safety performance in a manner that is clearly understood and echoed at all levels.
2. Management focus is a key to quality safety performance.
*1 & 2 above were seen as key factors
3. Existence of a company-wide framework or systematic, standardised approach to safety. The approach has performance standards that receive regular internal and external audits.
4. Objectives are set and organisations work towards set targets for implementation of the objectives.
5. Safety personnel report in at the highest level in the organisations. They have mainly an advisory function. Management and supervision drives the safety program not the safety personnel.
6 Effective safety training targeted to identified needs at all levels. Induction training and detailed safety training for supervisors and managers was high on the priority list. Regular safety meetings were seen as important.
7 Active personal involvement of senior management personnel in the safety program.
8 Safety is considered in performance evaluations of all staff.
9 Regular, detailed audits of the safety management system.
10 Formal approaches to hazard identification and risk analysis, employees were fully involved in this.
11 Formal emergency response procedures that were practiced and audited.
12 The best in class addressed contractor safety before contractors were allowed on site, they pre-qualified them based on safety and made safety performance a contract condition. Contractors were expected to perform at the same safety level as permanent employees.
13 High on the list of the ways the best in class built safety awareness were management participation and leadership, dissemination of information, safety meetings and rewards or recognition of performance.
14 Safety is a condition of employment and dismissals occur for non-performance.
15 Well-managed rehabilitation programs are in place.
16 The best in class use medical examinations and testing to ensure fitness for duty.
17 There were E.A.P’s in place.
18 There were off the job safety programs.
19 There was an emphasis on vehicle / plant maintenance and driver / operator training programs.
20 There were extensive PPE training, maintenance and audit programs.
21 Lock-out procedures were used instead of tag-out.
22 Best in class managers and supervisors respond positively to safety issues that are raised.
23 Best in class supervisors are responsible for safety auditing, investigating personal damage occurrences(accidents), planned job observations and training.
24 All levels in the organisation make decisions that reflect the philosophy “Safety first-Production will follow”.
It is suggested Safety Management Systems be built around the above benchmarking findings.