Before implementing policies or procedures, strategies for establishing environmental, health, and safety (EHS) accountability should be carefully considered.
Before implementing policies or procedures, strategies for establishing environmental, health, and safety (EHS) accountability should be carefully considered. Efforts can easily be misguided, causing EHS costs to rise and middle managers to be unnecessarily frustrated.
The following discussion is not for companies boasting well defined accountability programs that show excellent safety results. Company officers pondering intractable safety records, however, that simply will not improve may wish to consider the proposed EHS accountability program. It defines responsibilities and accountability, providing in effect a measurement of responsibility fulfillment.
In last month’s Compliance Matters, responsibility for the incident rate was placed squarely on the shoulders of the company president. That assignment is inevitable, since EHS compliance entails cost and must be implemented into work processes; and, the finances and level of effort to be expended hinge on approval by the company president. Further, the EHS manager can only effect the administration of safety programs, as operations management and personnel answer ultimately to the president. Accordingly, the notion that the EHS manager should sell safety is a cop-out on the president’s part. An old expression widely circulated among EHS managers wryly observes, We are given the responsibility [for the incident rate], but not the authority [to effect change].
Who should be held responsible, then, and what are the areas of responsibility? When a policy or system is not documented, assigned responsibility that comes under pressure Û as often occurs following an incident Û suddenly falls as blame typically on personnel who can’t easily defend themselves. Following are recommended basic guidelines for the development of an accountability policy.
EHS RESPONSIBILITIES, ACCOUNTABILITY
Summarized below are the basic responsibilities of each position and the parameters measured to evaluate accountability.
Primary EHS responsibility
- Incidence rate
- Loss rate
- Measured by the company incidence rate compared to the industry rate
- Measured by the loss runs, which provide direct financial losses that can be plotted to establish loss trends.
Plant Manager [Facility Manager or other title for the person responsible for the entire facility]
Primary EHS responsibilities
- Assure the implementation of safety work processes in the plant
- Assure EHS policy implementation on the floor/at the plant
- Implementation of time and resource availability for local EHS training, inspections, corrective actions, and other EHS program requirements.
- Compliance with company EHS policies, procedures, and process implementation per external audit
- Verification of employee EHS training completion documentation
- Verification of effective safety inspection and safety meeting completions
Primary EHS responsibility
- Hiring personnel in accordance with HR and EHS requirements.
- Supervising personnel for effective implementation of the EHS program into the work process according to the freedoms and restrictions provided by the plant manager
- Measured by external audit of personnel records documentation for company hiring procedures such as back ground checks, drug tests, references verification, physical exams, and/or similar company requirements
- Turnover rate evaluation by HR (only issues that are supervisor-related should be considered)
Plant Safety Coordinator
- Administration of the EHS program on the floor/in the plant
- Measured by the completion of local requirements for items such as incentive program implementation, bulletin board update maintenance, emergency plan maintenance and documentation, PPE availability, and effective management of claims
Primary EHS responsibilities
- Administration of the EHS program
- Maintenance of EHS policies that meet regulatory compliance
- Effective communication of incident trends, regulatory changes, best practices
- Measured by external audits of policies and programs, maintenance of EHS processes, regulatory compliance, housekeeping, and similar EHS considerations
- Evaluation by plant managers regarding the effectiveness of EHS communications (note: this is not an evaluation based on the incidence rate)
Primary EHS responsibility
- Working in a manner that complies with the company EHS policies as administered by the supervisor
- Working in a manner that prevents self-inflicted injury or injury to others
- Measured by EHS work process noncompliance documentation by the supervisor
- Measured by EHS program noncompliance documentation with established self-responsibility programs, such as the drug program, incident reporting, PPE use, following established plant safe work practices, and similar supervisor-established requirements
An effective safety process or program is often hampered by variables not readily subject to company control. Limiting conditions may include the unavailability of a qualified work force, pay restrictions due to such factors as low profits caused by drastic competitive pricing, the area drug-use culture, as well as seasonal business cycles leading to elevated labor turnover rates.
Problem Û Too many employees are suffering self-inflicted injuries by violating safety practices or by committing stupid mistakes.
Cause: If the problem is localized, improper hiring or a similar lapse in supervisory judgment could be the culprit. When such miscalculation is not evident, local management might be compromising safety by creating a hurry-up atmosphere.
Indeed, a compromised safety process can easily lead to a companywide problem, which frequently is the case when operations managers are heard to say, We don’t want anyone to get hurt. Because no one would attest to the contrary, the statement begs the question of why such a remark would be made. If injury-prevention strategies are not adequately incorporated into work procedures or if minimal effort is expended in the safety process, that affirmation may be the company’s sole, belated defense.
The investigating manager is encouraged to determine whether injured workers, as well as other employees, were previously counseled regarding violation of the particular work process. If counseling was received, the next consideration would be why they were not submitted to a graduated disciplinary process.
Problem Û The plant receives a negative EHS audit despite excellent long-term safety results.
Cause: If the audit reveals issues that need correcting where the company was previously compliant, an investigation into the cause of the sudden noncompliance is recommended. If the changes required are overly detailed, however, consider the problem to be a detailed auditor. In the second case, the manager might wish to simply correct legitimate items identified in the audit.
Problem Û OSHA issues citations to a plant that has previously received good internal inspections and external audits.
Cause: That’s OSHA! Any plant can be cited for a host of issues, despite best efforts toward 100 percent compliance. The OSHA inspector may consider two to three citations minimum to be a good number to issue at most places, with significantly more citations for problematic companies. The plant is advised to simply negotiate the issues as reasonably as practical, correct them, make efforts to ensure the violations do not reoccur Û and don’t lose any sleep over it.
Problem Û The safety inspector or auditor discovers an unofficial announcement or other veiled effort by the plant to suddenly meet full compliance for the sake of an inspection or audit.
Cause: Management is compromising safety. The source can be tracked backward starting with the supervisor, but the astute safety manager will let operations management follow up in such a predicament. An external inspection or audit for improvement is typically welcomed by any facility implementing a well-run EHS program and plant process.
Problem Û An external safety inspection reveals numerous routine items that have been in noncompliance for some length of time, but have never been identified on internal inspections.
Cause: Management is again compromising safety, as open violations are typically not being corrected due to cost. Frequently, a local safety coordinator will be in a position to know that identifying too many inspection items or citing a problem that is expensive to correct will bring immediate reprimand or disapproval from the local manager. In such a situation, the safety manager can greatly assist the local safety coordinator by identifying the items needing correction and requesting a correction or compliance schedule. Under those conditions, pushback can be expected. If the pushback is invalid but tolerated by upper management, or upper management does not want to contend with the issues, then a problem lies higher in the organizational structure.
Problem Û Safety meetings do not receive employee input.
Cause: Such indifference is usually an indication of management or supervisory lapses that have generated a plant culture of apathy. For example, a supervisor who conducts meetings with no enthusiasm or delegates leadership to the plant safety coordinator, sometimes skipping the meetings himself, may contribute to employees’ lack of interest. Other causes may include a lack of supervisory safety support, failure to follow-up on legitimate employee input, and/or a local culture recognizing only positive feedback, which considers safety recommendations negative.
Problem Û Incident-contributing causes are always blamed on the injured employee.
Cause: Sacrificing the employee is typical of pressured supervisors or plant managers who feel they must deflect responsibility for the incident. Reasons can include an overly defensive attitude, pressure to maintain a low incidence rate, or upper management’s position that the plant is solely responsible for the incidence rate. If the problem is companywide, the safety manager may be under pressure of being held responsible for the incidence rate.
In the end, all incidents cannot be controlled by the implementation of a carefully planned accountability program. Accidents will occur as long as risk is present, and some degree of risk remains in every action we take. A company with excellent safety results, however, will usually have a well-established accountability program in effect. Never more fitting than for safety accountability is the expression It comes from the top.