This material is for training purposes only. Its purpose is to inform employers and employees of best practices in occupational safety and health and general OSHA compliance requirements. This material is not a substitute for any provision of the Occupational Safety and Health Act or any standards issued by OSHA.
MODULE SIX: DEVELOP EFFECTIVE RECOMMENDATIONS
Introduction
An accident investigation is generally thought to be a reactive safety process because it is initiated only after an accident has occurred. However, if we propose recommendations that include effective immediate corrective actions and system improvements, we may transform the investigation into a valuable proactive process that ensures similar accidents do not recur. In this module we'll explore tips and tactics for making effective recommendations that "sell" safety improvements.
Do it right!
It's important to think of the recommendation process as a two-phase task. In phase one, we recommend corrective actions to eliminate or reduce the hazardous conditions and/or unsafe behaviors related to the accident. In the second phase we recommend system improvements to create or revise existing safety programs, policies, plans, processes and procedures identified as missing or inadequate in the investigation.
Some employers may assign the responsibility for making recommendations to safety directors or maintenance supervisors. However, you, as the accident investigator, may be required to take on this very important responsibility. Consequently, it's a good idea to know where to start, and how to write strong proposals. One tip up front: If you find the responsibility is yours, be sure to get the help of experts if you are unsure how to proceed. Consultants in OSHA or your workers' compensation insurer can great source for help.
To correct hazards - use the Hierarchy of Controls
To make sure recommendations are effective, we need to address effective control strategies that will eliminate or reduce the specific surface causes of the accident. In some instances, the investigator may actually be responsible to initiate as well as recommend these actions. Let's continue this discussion by taking a look at various hazard control strategies.
The Hierarchy of Controls
Hazard control strategies may be quite effective in eliminating hazards or reducing exposure. Effective corrective actions will include one or more of the following hazard control strategies:
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1. Engineering controls. Sometimes the cause of an accident is corrected most effectively by removing or reducing the hazard, itself. This may be done in a number of ways, including:
- Redesign the hazard out. Example - Fabricate a mesh guard to protect against exposure to moving parts.
- Replace the unsafe item with a safe item. Example - Replace a poor quality grinder stone with a high quality grinder stone.
- Enclose the hazard. Example - Place a hood over a source of noisy printer.
- Substitute an unsafe item with different item. Example - Substitute a toxic chemical with a non-toxic chemical.
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Engineering out the hazard is our top priority
Why is this control strategy our top priority? Employing an engineering control has the potential to completely remove the hazard. We're somehow changing a thing/condition in the workplace. And as we all know...
| No hazard...no exposure...no accident. |
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2. Work practice controls. This control strategy attempts to eliminate or reduce exposure to a hazard by controlling employee behavior. This is accomplished primarily through redesigning work practices and job procedures.
3. Administrative controls. This control strategy also attempts reduce exposure by limiting the duration of exposure to a hazard. To do this the employer may employ job rotation, and scheduling work/breaks.
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As you might have guessed, these control strategies are less effective in the long term than engineering controls because they do not remove the hazard, itself. Rather, they attempts to reduce exposure to hazards by controlling behavior - attempting to change "things we do or don't do." As long as employees "behave" or comply with the work practice or administrative changes, these control strategies will work. However, it's "normal" for us to want to work in the most efficient manner. Sometimes safe work procedures are not perceived as most efficient...so we may not use them. Managers must diligently oversee and maintain work practice and administrative controls or those controls will probably fail over time.
| "Any system that depends on human reliability is inherently unreliable."
A. Block, Murphy's Law Book Two
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4. Personal protective equipment (PPE). Some jobs require PPE by law. This control strategy is used in conjunction with the other control strategies. It should not be used to replace them. When engineering and/or administrative controls don't adequately eliminate or reduce the hazard(s)of a task, PPE may be needed in addition to those strategies. PPE places a barrier between workers and the hazard. Remember, PPE does not eliminate or reduce the hazard itself, it merely sets up a barrier between you and the hazard. And, to be successful, it is highly dependent on safe behaviors.
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The Hierarchy of Controls, when used separately or in combination, may be quite effective in eliminating or greatly reducing the probability of a similar accident recurring. However, to make sure long term risk reduction is achieved throughout the entire company, system improvements must be made.
Recommend system improvements
Missing or inadequate safety system components represent root causes for workplace accidents. Surface causes represent symptoms indicating system weaknesses. Therefore, every effort should be made to improve system components to ensure long term workplace safety. As we learned in the last module, the most successful accident investigator is actually a systems analyst: Not an easy task.
Making system improvements might include some of the following:
- Including "safety" in a mission statement.
- Improving safety policy so that it clearly establishes responsibility and accountability.
- Changing a work process so that checklists are used that include safety checks.
- Revising purchasing policy to include safety considerations as well as cost.
- Changing the safety inspection process to include all supervisors and employees.
Once again, it's a wise strategy to coordinate closely with those managers responsible for formulating system components when drafting recommendations.
Garbage In -- Garbage Out (GIGO)
When managers do not respond to a recommendation, it may be that they do not have enough useful information to take action. You've probably heard of the GIGO principle -- "If you put garbage in, you'll get garbage out." This principle, which is well known to computer programmers, applies equally well to the process of making effective safety recommendations: Useful information must be presented to management so they are better able to decide to take action.
Proactive recommendations
To speed up the process and to improve the approval rate, we must learn to anticipate the concerns and questions that the decision maker will have. The more pertinent the information included in the recommendation, the greater the likelihood for approval. To make sure you have the answers to those concerns and questions, ask some important proactive questions.
Answer Six Key Questions
Answer the following six questions to help develop and justify recommendations.
1. What exactly is the problem?
What are the specific hazardous conditions and unsafe work practices that caused the problem? What are system components - the inadequate or missing policies, processes, rules that allowed the conditions and practices to exist?
2. What is the history of the problem
Have similar accidents occurred previously? If so, probability for similar accidents is highly likely to certain. What are previous direct and indirect costs for similar accidents? How have similar accidents affected production and morale?
3. What are the solutions that would correct the problem?
What are the specific engineering, administrative and PPE controls that, when applied, will eliminate or at least reduce exposure to the hazardous conditions? What are the specific system improvements needed to ensure a long term fix?
4. Who is the decision maker?
Who is the person that can approve, authorize, and act on the corrective measures? What are the possible objections that he/she might have? What are the arguments that will be most effective in overcoming objections?
5. Why is that person doing safety?
It's important to know what is motivating the decision maker. Is the decision maker doing safety to:
- Fulfill the legal obligation? You may need to emphasize possible penalties if corrections are not made.
- Fulfill the fiscal obligation? You may want to emphasize the costs/benefits.
- Fulfill the moral obligation? You may want to emphasize improved morale, public relations.
6. What will be the cost/benefits if the recommendation is approved and the predictable cost/benefits if not?
What are the estimated costs and benefits of taking corrective action, as contrasted with the possible costs and harm that might occur if the hazardous conditions and unsafe work practices remain? What are the employer obligations under administrative law? What is the "message" sent to the workforce as a result of action or inaction?
The maintenance supervisor may be able to help you determine these estimates. Also, detail the costs associated with any training that might be required.
It's very important that we phrase the estimated expenditure required for the above corrective actions and safety system improvements an "investment." Why is this important? As you'll learn in the next module, it's the most appropriate term to use because this initial financial commitment may result in substantial returns to the company. These returns will be primarily realized as reduced future budgeted expenditures and unbudgeted losses.
Provide options
Finally, it's important to provide alternatives to make it more likely that corrective actions will be taken. Your options might follow the logic below:
- First option -- If we had all the money we needed, what could we do? Eliminate the hazard with primarily engineering controls. Additional administrative controls if required.
- Second option -- If we have limited funds, what would we do. Eliminate the hazard with primarily administrative controls. Engineering controls if required.
- Third option -- If we don't have any money, what can we do? Reduce exposure to the hazard with administrative controls and/or PPE.
Last words...
Remember, the most effective recommendations address corrective actions and system improvements. Although you may not be responsible for analyzing and evaluating safety systems for possible areas of improvement, make sure someone is. In most cases, the safety coordinator and/or safety committee are well equipped to take on systems analysis.
Now that you have an idea what effective recommendations look like, it's time you take the module review quiz.
Take the Review Quiz
