This paper was written by Leslie A. Miller for a graduate class in OAED (Occupational Adult Education) at Oklahoma State University. If you would like to copy/reproduce it, I would only ask that you leave the by-line and do not alter the material.
In the introduction to the guidelines, OSHA states: "Over their long years of experience with enforcing the provisions of the Occupational Safety and Health Act of 1970, OSHA representatives have noticed a strong correlation between the application of sound management practices in the operation of safety and health programs and a low incidence of occupational injuries and illnesses. Where effective safety and health management is practiced, injury and illness rates are significantly less than rates at comparable worksites where safety and health management is weak or non existent."
Additionally it says, "In 1982 OSHA began to approve worksites with exemplary safety and health management programs for participation in the Voluntary Protection Programs (VPP). Safety and health practices, procedures, and record keeping at participating sites were carefully evaluated and monitored by OSHA. These VPP worksites generally had lost-workday case rates that ranged from one-fifth to one-third the rates experienced by average worksites. Further, most participating sites reported improved employee morale and productivity as a by-product of their safety and health management activities."
In other words, the implementation of safety and health programs has been shown to significantly reduce the number of accidents, injuries, and illnesses occurring in the workplace, as well as to increase employee morale and productivity. These statistics were so compelling, in fact, that the Oklahoma State Legislature passed a provision in Oklahoma House Bill 1447 mandating all public employers in the state of Oklahoma with over 25 employees to implement a written safety and health program incorporating the provisions of the OSHA voluntary guidelines.
While the Oklahoma Department of Labor and Oklahoma Department of Vocational and Technical Education have produced an excellent Occupational Safety and Health Program manual which follows the OSHA guidelines; "Training for Performance System" (TPS) methods provide the safety coordinator or safety trainer with a comprehensive tool for effectively implementing a safety (training) program and truly making it work.
The OSHA guidelines identify four major elements of an effective safety program:
While the name "Training Performance System" might, at first glance, imply a relevance only to the fourth of these elements, the fact is that it directly involves all four. Obtaining management commitment is listed as the top priority in both the OSHA guidelines and the Department of VoTech's manual. Both recommend several actions necessary to getting management commitment and employee involvement. These include writing a worksite policy statement, establishing and communicating clear safety goals, providing visible top management participation, encouraging employee involvement, assigning responsibility, and providing a means of accountability.
Ideally, following these guidelines, the safety coordinator or trainer would be able to sit down, write the policy statement, present it to top management, get management's stamp of approval, implement the program with full employee involvement, and rewrite job descriptions to ensure responsibility and accountability. Unfortunately, most safety coordinators and trainers are operating under somewhat less than ideal circumstances. Despite the weight of statistical studies such as those cited by OSHA in their guidelines, as well as the threat of OSHA citations and fines, it is frequently exceedingly difficult to get upper management to commit time and resources to safety.
In organizations which don't already endorse safety as a high priority, it is probably the safety trainer's or coordinator's greatest challenge to get management commitment. Why is this? Basic systems thinking provides one clue: the safety coordinator and management have different desired outputs. For example, a custodial supervisor desires clean buildings at the end of the day, whereas the safety coordinator desires to reduce the number of back injuries occurring to custodial staff. The fundamental difficulty for the safety coordinator or trainer is to demonstrate to the custodial supervisor (or management) that these two seemingly different goals are in fact interrelated. It is not, however, an easy correlation to make, and this is probably why many safety coordinators fail to receive the management support they need to make a safety program successful.
Neither the OSHA guidelines nor the Department of VoTech's manual provide suggestions for how to go about attaining management commitment. If the safety coordinator does no further research on the subject, he or she is left knowing what needs to be done, but with no means to accomplish it. Because they know that obtaining management commitment is vitally necessary for program success, they fail before they ever begin, never getting past the "first" step.
This is where systems thinking comes into play. To obtain management commitment, the safety coordinator has to "sell" safety to management. Given management's desired output, the safety coordinator has to show that safety contributes to that desired output. Usually this means demonstrating that safety saves money, saves time, increases production, reduces costs, etc. How will safety benefit management's goals?
It is quite possible to put a price tag on safety if one knows where to look, and interestingly enough, by following TPS analysis methods to accomplish the Worksite Analysis and Hazard Prevention and Control portions of the OSHA guidelines, the safety coordinator is provided with the information necessary to determine that cost benefit. It is important to note, therefore, that when using TPS, obtaining management commitment is not necessarily the first step afterall. Conducting the worksite analysis and determining hazard prevention and controls will actually provide the information needed to get management's support.
Safety and health training is the last concern addressed in both the OSHA guidelines and the Department of VoTech's program manual. Yet training is the ultimate concern of TPS, and by using this system, many of the other elements of an effective safety program will fall into place. The object of the OSHA guidelines is, after all, improved performance in the realms of safety and health.
In the first stage of TPS, the safety coordinator or trainer must diagnose workplace performance in terms of safety. The coordinator must look for signs that safety hazards exist or unsafe procedures are being used, etc. Data may be collected from a variety of sources, but analyzing accident and injury reports such as the OSHA 200 log is critical for determining workplace trends and problem spots. (These reports will also provide information necessary to determine the average cost per accident, time lost, etc. needed to put together a performance improvement proposal.) For example, analyzing accident reports may reveal that custodial crews are experiencing a high rate of back injuries. This would warrant further investigation to find out why so many custodians are injuring their backs.
Interviewing and questioning employees about perceived safety problems may also be of use. Workers who actually use the tools and equipment at particular locations may know of problems of which management is completely unaware. The added benefit of soliciting their input at this stage is that it involves them in the safety program from the very beginning, something which OSHA notes is very important to any program's success.
Existing OSHA standards provide rules and regulations governing numerous safety issues which must be met regardless of all other factors. These are particularly useful in determining safety performance gaps which are not reflected by actual accidents, injuries, or employee perceptions. For example, OSHA may require that safety glasses be worn whenever employees use a grinding wheel. Chances are that even if employees do not wear their glasses while grinding, an injury will not result. Therefore accident and injury records may not reflect the fact that safety glasses are not routinely worn. If employees do not wear the glasses because they are uncomfortable or for other reasons, they are not likely to report it as a safety hazard, either. Yet to meet the requirements of law, safety glasses must be worn. This should be identified by the safety trainer or coordinator as a performance gap which needs to be addressed.
At this stage, the safety trainer or coordinator is attempting to analyze what and where the performance problems may be, and at what levels within the organization, etc. If no safety program is in existence, chances are that problems will be identified throughout the organization on various different levels. For example, an obvious problem that may be identified on an organizational level is that the organization doesn't have any safety program in effect. A small, specific, short term performance need might be to eliminate custodial back injuries.
While the OSHA guidelines suggest performing "job safety analyses" for all job positions, because of problems already identified - the different desired outputs between safety and management, and the difficulties in obtaining management commitment to a blanket program - it may be more productive for the safety trainer or coordinator to initially focus on small, specific, short term performance needs. Larger problems can be addressed after the successful correction of smaller needs. Management is more likely to support proposals that have a direct and immediate impact on time, quantity, or quality... the bottom line in all cases being money or financial benefit of some sort.
Pick a safety problem which has significant impact on one of these things. For example, back injuries are, on average, the most expensive injuries in terms of medical expenses, worker's compensation costs, and lost time and productivity. They are also the most common type of industrial injury. If accident and injury records indicate a problem with back injuries, that might be one place to start.
At this point it becomes necessary to move into the TPS work behavior analysis stage. It is during this stage that the OSHA guideline elements of Worksite Analysis and Hazard Prevention and Control will be addressed. OSHA recommends performing routine job safety analyses as a primary step of Worksite Analysis. The VoTech manual describes this process as "breaking down a specific job into its component steps and listing them in order. From this point, you can determine whether the job could be done without any hazards, as well as the steps to take to eliminate the hazards." (Occupational Safety and Health Program Manual, module 7, page 6)
Needless to say, TPS provides a far more comprehensive means of doing this, consequently providing the safety trainer or coordinator with far more powerful tools for achieving performance improvement. TPS work behavior analysis is based upon documenting workplace expertise. The five tools for documenting workplace expertise are:
Of most benefit to the safety coordinator or trainer will be the job description/task inventory, procedural work analysis, and the systems work analysis. The type of problem or performance gap being addressed will indicate which tool is needed to determine its cause.
Various OSHA regulations may apply to specific job tasks, thereby indicating specific performance needs. For example, welding or brazing operations require the use of tinted goggles or welding masks. A quick glance at a job description may be enough to determine whether or not an individual performs welding or brazing operations, thereby indicating a need to bring performance into compliance with the required standard. This becomes especially useful when trying to address an OSHA regulation based performance gap effecting numerous employees. An example of such a requirement might be the "Bloodborne Pathogen Standard" where any employee who might reasonably come in contact with blood or body fluids during the course of their job duties must be trained in universal precautions and other procedures.
A procedural work analysis takes a specific task from a job description's task inventory and breaks it down into its sequential steps. This is important because reported accidents or injuries will often be associated with specific tasks. For example, "pulling beds" or "carrying sheetrock" may frequently be listed as a cause of back injuries; or "cleaning bathrooms" may frequently be associated with chemical burns. By breaking the task down into its sequential steps, it may become obvious as to why such injuries occur. For example, it may be determined that in order to "pull the bed", the housekeeper must crouch down in an awkward position to grab the bed frame in order to pull the bed out from the wall; or that "carrying sheet rock" can cause back injuries because sheet rock is heavy, awkward, and must be carried up stairways to upper floors because it won't fit in elevators.
Similarly, specific tasks may be associated with specific injuries. Accident/injury reports may indicate a trend in eye injuries resulting from "moving ceiling tiles", or numerous injuries caused by slips while "working on ladders". If a procedural work analysis indicates that certain changes can be made to eliminate these problems, the safety trainer or coordinator can use job descriptions and task inventories to determine which employees are likely to use ladders or move ceiling tiles.
A systems analysis may be used if the problem seems to be system related. For example, if employees report that they are frequently sent to do tasks for which they are not adequately trained thereby jeopardizing their health and safety; it may be necessary for the safety trainer or coordinator to perform a systems analysis to determine why this is occurring. The information provided by these analyses should give a fairly good indication as to what the exact problem is. Finding the correct solution to the problem falls under the OSHA guideline element of Hazard Prevention and Control. Here, the safety trainer or coordinator must apply the industrial hygiene hierarchy theory of control technology. This theory states that when addressing safety hazards, a specific order of control technology should be utilized. The various different controls are, in order:
An example of how this hierarchy works might be illustrated by examining the chemical burns resulting from cleaning bathrooms. By performing a procedural work analysis, it was determined that when housekeepers wash bathroom walls above their heads, the cleaning solution runs down their hands and arms, burning any exposed skin. Wearing gloves protects their hands, but not the rest of their arms.
The hierarchy theory dictates that engineering controls should be looked at first when considering possible solutions to this problem. Engineer controls modify the work environment or job itself to eliminate or reduce employee exposure to hazards. Potential engineering controls for this particular problem might be eliminating the need to clean the walls above a certain height, changing cleaning products to something not as caustic, or using long-handled brushes so that the housekeepers' arms are not held at an upward angle while performing the work.
Going down the list of potential controls, the use of additional personal protective equipment in the form of longer gloves or chemical resistant sleeves might be suggested if engineering controls prove ineffective or inappropriate. Finally, a remedial control might be telling employees to wash their hands and arms with soap and water after any exposure to chemical cleaning products.
If the proposed solutions to safety problems include changes to employee knowledge, attitudes, or skills,Safety and Health Training will be needed in some form or fashion. The safety trainer or coordinator must then determine what type of training will be most effective, either structured or unstructured, etc. He or she will also have to determine such factors as the form of presentation and the training content.
Once the safety trainer or coordinator has conducted the complete performance diagnosis, he or she must construct a performance improvement proposal. This is where a cost value is finally assigned and the complete plan of action presented to management. By showing statistics on time lost caused by various types of accidents and injuries or quoting average costs of OSHA citations, etc., it should be possible to demonstrate the cost effectiveness of safety training and safety programs.
Ideally, the benefits of recommended changes will be so obvious that management will embrace the proposed project(s) with little resistance. If the first performance improvement proposal is endorsed and proves successful, the safety trainer or coordinator should find soliciting approval for subsequent projects progressively easier. Eventually management may embrace a proposal for an all-encompassing safety program incorporating all aspects of OSHA's recommended guidelines.
By following TPS models, the safety trainer or coordinator is provided with all the tools necessary to meet the elements necessary for a successful health and safety program as described in OSHA guidelines. TPS tools are more powerful and more specific (and therefore more useful) than similar tools outlined in the Department of Vocational Technical Education's Occupational Health and Safety Program Manual. While the TPS model descriptions, industrial hygiene controls, and safety hazard examples provided in this paper are generalized at best, any safety trainer or coordinator familiar with TPS should be able to utilize it to improve safety and health performance in their workplace.
