As you know, by now safety is important, but only addressing individual incidents and safety hazards will not change your company safety culture or have much of an impact on core safety issues.
To take control of your company's safety culture, you must perform a safety audit.
A safety audit is a methodical examination and review of your company's safety program. The task of a safety audit may seem daunting, but don't let the thought overwhelm you. If you are considering a safety audit at your company you must first decide if you will have a private safety company conduct the audit if you will do it yourself. Outside companies are great when there is no safety expert on staff or when a third objective view is needed.
A safety audit looks at all of the different aspects of the company safety program and its effectiveness. OSHA states that the effectiveness of a safety and health program depends on the credibility of management's involvement in the program; inclusion of employees in safety and health decisions; rigorous worksite analysis to identify hazards and potential hazards, including those which could result from a change in worksite conditions or practices; stringent prevention and control measures and thorough training. It also addresses whether or not hazards are regulated by government standards. A safety audit must cover all of these aspects to be effective.
You may choose to audit specific jobsites, divisions of your company or the company as a whole. However large or small your audit, the best way to structure the audit is along the Plan-Do-Check-Act cycle guideline. The concept is simple, yet very effective and covers the following five points:
- Occupational Safety & Health (OSH) Policy-(Plan)
- Planning-(Plan)
- Implementation and operation-(Do)
- Checking and corrective action-(Check)
- Management review-(Act)
1) OSH Policy
Is the OSH Policy integrated with business unit systems and policy implementation programs? Are safety needs a core company value-something that can't be compromised-and as such should it be ingrained in all other aspects of company operation?
Does the OSH Policy include the commitment to provide sufficient and appropriate resources? As a manager or owner, you may think so, but if you have a safety director, ask them this question with a request for open feedback with no fear of reprisal. You may be surprised that they feel the $100,000 yearly safety budget, when divided among individual projects, is very inadequate and may be costing your company more money in accidents, injuries, lost time and employee morale than the few extra dollars he needs. Recently, a Jacksonville based underground utilities contractor, reduced their hand injuries to zero by investing in higher quality gloves for their employees. Previously, hand injuries topped the list as their No. 1 injury on the job!
Is the policy communicated to all employees with the intent of making them aware of their individual OSH obligations? (This should be conducted through a random sampling of employees with different levels of tenure at the company.) Often times, training is conducted through third parties with no management presence during training or follow-up. Having management visible and directly involved and engaged is the best training session any company can have. This reaffirms the management commitment to safety and the program.
Can employees demonstrate an understanding of the organization's policy (again, based on sampling)?
Is the policy available to other interested parties (e.g., sub-contractors, developers, suppliers)?
2) Planning (for hazard identification, risk assessment and risk control)
Do all major activities have safe work procedures or other effective control measures developed and implemented based on the relevant risk assessment? Be sure that your company has a risk assessment for all stages/phases of operation and types of work your employees do. You should pick at least three major activities and check for safe work procedures.
Are the risk assessments conducted by personnel who have adequate knowledge of the activities involved? A Job Hazard Analysis (JHA) should be conducted by qualified personnel or consultants for the following types of work:
- Jobs with the highest injury or illness rates
- Jobs with the potential to cause severe or disabling injuries or illness, even if there is no history of previous accidents
- Jobs in which one simple human error could lead to a severe accident or injury
- Jobs that are new to the operation or have undergone changes in processes and procedures; and
- Jobs complex enough to require written instructions
Are relevant personnel (e.g., direct employees, sub-contractors, suppliers, consultants) aware of the legal and other (e.g., subcontractor contract) OSH requirements that they must comply with? Is training being conducted as required by OSHA? Are there established procedures to identify training needs and provide adequate safety training? Are subcontractors employees aware of safety rules (hardhats, safety glasses, etc.) for the jobsite and your company? This should be dictated in the contract, but often does not make it down the chain to the workers unless made a priority by the hiring company.
3) Implementation and Operation
Is there clear evidence that the management is committed to continual improvement of OSH performance? This goes back to the policy but actually looks at the follow-through of management commitment to the program. One company that I work with starts every meeting in the company, no matter how large or small, with a "Safety Moment." The "Safety Moment" can come from anyone participating in the meeting and may be a safe act seen by an employee, a hazard on an upcoming task, work completed safely, a safety recommendation, etc. This clearly demonstrates that safety always comes first no matter the topic of discussion.
Are there measures to ensure that personnel who have OSH responsibilities are free from potential discrimination that could result from execution of their OSH duties? Often, employees feel they can not report a hazard to management. For example, if additional safety equipment is needed on a job or tight schedules and a cranky superintendent may get in the way of better judgment. Be sure that safety is always first, and if an unforeseen issue comes up, the penalty for not reporting the condition always outweighs the fear of reporting it.
Another reason employees may not report an injury or safety hazard is because of the actual safety program itself. Unfortunately, "effective" safety programs can sometimes discourage employees from making a report because the program is structured in such a way that employees are penalized and incentives are taken away if there is an injury or safety violation.
Are personnel consulted when there are changes that affect workplace safety and health? Another key point many companies overlook is the actual employee. The workers performing the task are often a great source of information to find what may make a job easier, safer or an employee more productive.
4) Checking and Corrective Action
Are personnel at all levels aware of the key OSH performance indicators of the organization? A great way to do this is to include Occupational Safety KPI's or even just injuries or lack thereof in company reports and meetings when determining how a job or year is progressing. The KPI's will help you determine direction and any actions that are needed to keep on track.
Do auditors follow strictly to the audit procedures? If you have audits which contain false or misleading information because the wrong people are conducting the audits, the audit may do you more harm than good. The best person to conduct the audit is an uninterested third party either within your company or outside of it.
Are deficiencies in the hazard control system or new hazards or risks found during audits and self-inspections and then reported immediately to the individual(s) responsible for performing preventive and corrective actions? After you receive your audit back for management review, ask the responsible party if they were notified after the audit of the unsafe situation noted on the audit and what they are doing to correct it. The best way to correct a problem is through prompt notification to the party that has the authority to inspect and correct it immediately.
Is management reviewing findings and using them to initiate preventive and corrective actions? If safety issues are put on the back-burner, injuries are sure to result and employees will see the lack of management commitment to the safety program.
5) Management Review
Is the management review documented and disseminated to personnel with OSH responsibilities and relevant parties? The audit should not be kept private. There should be a formal e-mail, meeting, company mailing, etc., covering some of the hazards found on different jobs and divisions and how the hazards will be corrected. This should also be accompanied with a reaffirmation of management's commitment to safety, incentive programs for safe employees and teams and corrective actions for safety violations.
Establishing a safety culture is sometimes not an easy task. Some employees who are set in their ways may be difficult to sway to the new way of doing things. Job processes may need to be changed, and policies may need to be modified, but through commitment and example, it can happen. The safety audit is a fantastic tool to put in your company arsenal. It will not only give you a greater insight into your company's safety effectiveness, but it will also give you a great insight into the operation of the company.
Construction Business Owner, October 2008
