Do This, Don’t Do That, Our Experts Recommend
You’ve taken courses, attended safety conferences, and listened to webinars. However, there’s nothing like the experiences of those who have “been there and done” what you’re trying to do. So, in this Compliance Report, we have asked the experts—the health and safety directors at the world’s largest package delivery company and a longtime private consultant.
They share real-world recommendations for building a more effective safety and health organizational process, such as making sure that a focus on behavior change doesn’t get in the way of essential activities, like equipment maintenance, and fully empowering employees to find and fix hazards locally. You’ll also learn what a “safety zone” is and why combining safety and health with other management duties may be a bad idea.
CIRCLE SAFETY AND HEALTH CONSULTANTS
Anna Jolly is vice president and consultant with Circle Safety and Health Consultants of Richmond, Virginia. Jolly combines her OSH experience with a legal background to help small- and medium-size clients in general industry and construction. She also consults with municipal governments and a large federal agency.
“After law school, I worked for Virginia OSHA,” says Jolly. “And I spent a lot of time helping people make sense of the law and understanding their responsibilities.” As a consultant she continues to do the same.
Asked for “do this, don’t do that” recommendations, Jolly says, “One client had gotten very involved in a behavior-based program, which I think is great, but they were forgetting to pay attention to the facilities. In many cases, machines were breaking down, and the audit component was missing.” Putting all eggs in one basket—in this case, behavior change—isn’t the best strategy, Jolly believes.
The business used a well-recognized behavior observation process that has helped substantially reduce injuries, she said, “but I can still go in there on an audit and identify a lot of hazards relating to processes and equipment that hasn’t been maintained.” Some organizations become so focused on behavior or culture change that they ignore safety basics.
“When management pushes safety down to the line and first-supervisor levels, they need to fully understand the implication, Jolly says, reiterating that she finds “nothing wrong” with behavior-based processes. However, especially when staffing is low, she maintains that management needs to ensure that someone—an engineer, industrial hygienist, or outside consultant—has oversight for other parts of the program.
Otherwise, businesses open themselves up to costly OSHA inspections because things have slipped through the cracks. “You’ve put so much money into a behavior-based program, and you can’t imagine how you could end up in trouble,” she advises, adding that a safety organization does not run itself.
More than Common Sense
Jolly also urges safety and health professionals, supervisors, and front-line employees to make sure they’re fully versed in relevant OSHA regulations. Jolly has worked with some businesses, especially those that have “been around forever and always done things the same way,” that have the outdated view that safety is just common sense.
It’s a concept she encounters at all levels, from a laborer who resists understanding why he needs to know how fall protection equipment works to supervisors overseeing the digging of trenches without comprehensive knowledge of the trenching regulations.
“People look at me blankly and tell me the OSHA regs are too complicated. I respond that they don’t need to know everything, but they do need to know the relevant standards,” she emphasizes. “Safety is complicated, and it’s not just common sense.”
This advice also applies to the compliance process. “One of the things that disturbs me is the number of safety and health professionals who don’t really understand compliance. They don’t pick up the OSHA manual and address areas of concern,” says Jolly.
Many professionals lack knowledge about how an OSHA inspection works or the rights of employers and employees during an investigation. They may not even realize, for example, that OSHA cannot typically conduct a wall-to-wall inspection if it has come in response to a specific complaint. Such basic knowledge is essential in running a safety and health organization at a business of any size.
Jolly has also observed confusion over issues like the need for a certified hazard assessment in order to determine PPE or the requirement for machine-specific lockout/tagout devices. She advises safety and health professionals to become familiar with OSHA regulations and interpretations, recognizing that agency standards represent the minimum of compliance.
Doing More with Less
With safety and health staffs reduced at many workplaces, doing more with less has never been a more widespread practice. Jolly has long been a proponent of using such resources as the OSHA website and state-run consultation and training programs. She urges clients to get their names on e-mail and mailing lists that promote information sharing and to get involved in their trade and safety and health associations.
Although she believes insurance providers can be an excellent and affordable resource, Jolly stresses the important differences between an insurance inspection and a compliance inspection. “The insurance company is interested in losses, and these inspections tend to be more generalized. A compliance audit is very detailed and is done much the same way an OSHA audit would be done,” she explains. Both audits are important and should be done if possible.
Of course, doing more with less sometimes means that safety and health professionals wear multiple hats. Jolly is wary of combining safety and health with environmental duties, a common practice at smaller companies. “If your company is of any size at all, I don’t see that this can work because one co-opts the other,” she states. What typically happens is that safety and health get short shrift when lumped with environmental oversight.
Jolly says that’s because EPA regulations are generally harder to comply with than OSHA’s and require more paperwork; failure to follow them results in higher penalties.
“You could have a structure with an environmental manager, a safety and health manager, and someone over both of them,” she maintains. “But often when somebody says they have oversight for both areas, we discover at the end of the year that they’ve spent all their time on the environment, and safety and health suffer.”
There’s an unfortunate perception that environmental compliance is more important than safety. That results in part from the fact that environmental misdeeds can be dramatic and often attract negative media attention.
Explains Jolly, “When it comes to safety, you’re not going to get bad press unless you kill someone.” -
Similarly, she warns against lumping safety with human resources duties. HR professionals enter that field because of their specific interests and skills, but those don’t necessarily translate to a passion for the “messy, dirty” work of safety, in her opinion.
Debbie Gehricke, Emilio Lopez
UPS, the world’s largest package carrier, was founded in 1907 as a messenger company. Today, UPS, formerly United Parcel Service, is a global provider of specialized transportation and logistics in 200 countries worldwide. We asked Debbie Gehricke, director of global health and safety, and Emilio Lopez, director of fleet safety, what to do and what to avoid in a top safety and health program.
Both point without hesitation to empowering employees, which UPS does through its Comprehensive Health and Safety Process, or CHSP. The structure dates from 1995 and focuses on permitting employees, supported by management, to directly influence safety. The process has made a dramatic difference for the package giant in both accident rates and vehicle crashes.
UPS cites a 33 percent reduction in auto accidents and a 40 percent drop in injuries since 2006. While most companies lack the size and resources of UPS, Gehricke and Lopez believe the CHSP principles can be applied to much smaller operations.
The backbone of the process is the nearly 4,000 CHSP committees at UPS facilities around the world. They are typically led by a non-management employee supported by a management co-chair.
Not Your Father’s Safety Committee
The process charges employees at the local level with finding and fixing problems. Committees determine root causes and create action plans. Gehricke describes a recent CHSP driver meeting she attended at a local operations site in New York City. The group was tackling the issue of hit-while-parked delivery trucks. The problem was exacerbated by the piles of late winter snow that reduced available space for parking and driving on already narrow city streets.
The committee came up with a strategy that involved plotting the accident sites. Information about the accident patterns and locations would be communicated with other drivers. Committee members would conduct demonstrations to remind their colleagues about proper parking.
Local CHSP actions sometimes drive corporate decisions. The hit-while-parked issue is an example. Several local district operations were successful in reducing these accidents by installing various devices. Local solutions included installing orange cones behind the trucks and attaching orange flags to the top near the rear of the truck.
A California CHSP used a fluorescent wrap around the spring bumpers’ upper support arm to alert oncoming traffic. Based on the success of these innovations, corporate decided to invest in blinking strobes built into the taillights of UPS package trucks in major metro areas.
Making Things Happen
CHSP committees are fully empowered to take action. This sets them apart from traditional safety committees led by managers “who basically told people to quit getting hurt.” CHSP turns that around by expecting employees to make the changes that will keep them from getting hurt. Management is always available for support, but the real action takes place with frontline decision makers.
“Wherever we see an issue we fix it,” says Gehricke. “There’s always that engagement. The groups have authority to make things happen.” Employees take concerns directly to their CHSP representative, who shares them with the committee. An item remains on the agenda until it is resolved.
CHSP committee members are also involved in long-term planning. Each group develops a 15-month action plan to tackle long-term safety goals. But the plans are flexible enough to accommodate emerging issues. When problems arise, attention turns away from the 15-month plan and toward the immediate needs.
The groups serve other purposes, too. For example, a wellness champion has been identified within each CHSP committee. These individuals are points of contact for wellness information and activities like health fairs, screenings, and communications. Their role will become even more important as UPS gears up to introduce a corporate wellness initiative.
Gehricke and Lopez believe the committee structure is the single most important component of their safety process and recommend the full empowerment model to other safety and health organizations.
Do Try This at Home
Asked about other best practices, Gehricke explains that every UPS meeting has a “safety share” or tip. It’s a technique used by many safety-minded companies and one that Gehricke insists makes a difference at UPS. Subjects might be railroad crossing risks, distracted driving, or safe lifting. The exchange is brief, but the consistency of the practice underscores management’s commitment to keeping workers safe.
“We go one step further,” explains Gehricke. “Every day at every UPS operation, drivers gather for a 3-minute communication that might address a new service or other key information they need. At the end, we always include a safety tip.” The content is decided locally—here, too, the value is in the consistency of the practice.
UPS has developed a behavioral safety process said to be a factor in injury reduction. The company partnered with Liberty Mutual to create an observation and feedback program. Over the past year, employees have conducted more than a million observations. The findings are fed back to the CHSP committees, which use them to develop goals and programming.
In 2006, UPS introduced an innovative practice that created “safety zones” at all locations. A safety zone is a physically delineated area where drivers and other workers gather. The zones may include computers for online research, information boards, and space for holding safety presentations. Some locations have even introduced light workout equipment.
Gehricke says carving out a dedicated space devoted to safety helps underscore its importance and makes the commitment visible. She says the zones were not costly to create and are definitely proving their value.
UPS is also a believer in promoting from the ranks. The company, known for employee longevity, encourages employees to grow in safety as they grow in their jobs. It’s not unusual for a part-time loader to become a driver, then a supervisor, and then a manager, with safety responsibilities added along the way. Encouraging long-term employees to take on safety duties helps create buy-in and strengthens the safety organization.
SLOW AND STEADY
Talking with experts like Anna Jolly from Circle Safety and Debbie Gehricke and Emilio Lopez from UPS reinforces the idea that achieving world-class safety and health is a long-term process. There’s no next great thing, no silver bullet that drives excellence. Rather, as these leaders attest, it’s a matter of being open to new ways while remaining vigilant about the basics.