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This material is for training purposes only to inform the reader of occupational safety and health best practices and general compliance requirements and is not a substitute for provisions of the OSH Act of 1970 or any governmental regulatory agency.
 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 helps to prevent future injuries. In this module we'll explore tips and tactics for making effective recommendations that "sell" safety improvements.
Do it right!
It's important to divide your recommendations into two categories:
- First, recommend corrective actions to eliminate or reduce the hazardous conditions and/or unsafe behaviors related to the accident.
- Secondly, recommend system improvements to create or revise existing safety policies, programs plans, processes, procedures and practices identified as missing or inadequate in the investigation.
Some employers may assign the responsibility for making recommendations to safety directors or other managers. 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 recommendations. 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. OSHA consultants, other safety professionals or your workers' compensation insurer can be a great source for help.
Make recommendations to eliminate surface causes
To make sure recommendations are effective, you need to recommend effective hazard control strategies that will hopefully eliminate the surface causes of the accident. In some instances, you may actually be responsible to make recommendations and initiate those recommendations. Let's continue this discussion by taking a look at various hazard control strategies.
Hazard control strategies may be quite effective in eliminating hazards or reducing exposure if they are based on the guidelines in ANSI/AIHA Z10-2005 - Occupational Health and Safety Management Systems. Here are two important points to remember about the six strategies detailed in the standard:
- Engineering Strategies 1-3 are usually most effective because they attempt to control the hazard, itself.
- Behavioral Strategies 4-6 are generally less effective because they attempt to employee behavior rather than the hazard.
The Hierarchy of Control Strategies
Let's discuss the six hazard control strategies that I've grouped into the two categories described above. As a safety professional, you need to be familiar with these basic strategies. You can be sure they'll be on the exam :-)
Higher priority strategies that control hazards
1. Elimination. Totally eliminate the hazard. (no hazard - no accident) 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. |
- Design. Example - Design a tool so that it reduces the likelihood of an strain or sprain.
- Redesign. Example - Change the design of a machine so that dangerous moving parts or electrical circuits are out of reach.
- Enclosure. Examples - Place a hood over a source of noisy printer. Place a machine guard around a dangerous moving part.
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It's important to note that OSHA expects the employer to first try to eliminate, substitute or engineer the hazard so that it no longer cause a serious injury. For instance, if a machine is producing unacceptable noise, OSHA would expect the employer to first eliminate or reduce the noise level to acceptable levels using one or more of these three strategies. In this instance, an engineering control such as enclosure might work.
Lower priority strategies to control behaviors
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4. Warnings. Signs and labels that tell employees to "Keep Out," "May cause eye irritation" etc., are used to warn employees about hazards. Note: Employees do not necessarily follow "posted" rules and warnings. They usually only follow "enforced" rules and warnings. Think about that the next time you're driving down the highway. Do you drive at the posted speed limit, or the enforced speed limit. Enough said.
5. 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. This is also accomplished through improving work procedures and practices. Examples - Develop and use a safe work procedure for preventive maintenance on air conditioning equipment.
6. Personal protective equipment (PPE). Some jobs require PPE by law. PPE places a barrier between workers and the hazard. This control strategy is used in conjunction with the other control strategies. It should not be used to replace them. When other controls do not adequately eliminate or reduce hazards, PPE may be needed in addition to those strategies. 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 the employee's behavior.
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The final three control strategies are less effective than elimination, substitution, and engineering controls in the long term because they do not remove the hazard, itself. Rather, they merely attempt 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 warning signs, administrative controls and wear PPE when required these control strategies will work. However, human beings are natural risk-takers, and it's "normal" for us to want to work in the most efficient manner. Sometimes safe work procedures are not perceived as efficient, so we may not want to use them. Therefore, managers must regularly supervise employees to make sure they comply with warning signs, procedures and PPE requirements. Think about the "Murphy's Law" principle below. It certainly applies to safety.
| "Any system that relies on human behavior is inherently unreliable."
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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 future similar accident. However, to make sure long term risk reduction is achieved throughout the entire company, safety management system improvements must be made, so let's discuss this important topic.
Recommend system improvements
The surface causes for accidents we've been discussing actually represent the symptoms or effects of underlying safety management system weaknesses or root causes. This cause-effect relationship is so important to understand that I'll say it again: the behaviors and conditions that caused the accident are, themselves, usually the effects of deeper root causes. This is a fact.
Consequently, your first assumption, as an accident investigator, should be that root causes have contributed to an accident, and your job is to find them. Your first basic assumption should never be that an accident is simply the result surface causes. Once in a while, you'll find that an accident was solely the result of a "personal failure," but that won't be often: in fact, it will be rare in most organizations.
Therefore, make every effort to improve safety management system components to ensure long term workplace safety in your company. As we learned in the last module, the most successful accident investigator is actually a systems analyst. Making safety management system improvements might include some of the following examples:
- 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
- Including hands-on practice as part of the safety training program
- Revising purchasing policy to include safety considerations as well as cost
- Changing the safety inspection process to include all supervisors and employees
"GIGO" or "QIQO"?
Here's another idea to think about. 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." That also works on the flip side. Quality in - Quality out or "QIQO". Useful information presented to management is more likely to result in decisions that take effective action to make long-lasting positive improvement.
Proactive recommendations
To speed up the process and improve the approval rate, learn to anticipate the concerns and questions that the decision-maker will have. The more pertinent the information is to the decision-maker, the greater he or she is likely to approve it. To make sure you have the answers to the decision-maker's concerns and questions, ask some important proactive questions.
Answer Key Questions
Answer the following questions to help develop and justify recommendations.
- What exactly is the problem?
- What is the history of the problem
- What are the solutions that would correct the problem?
- What motivates the decision-maker to "do" safety?
- What will be the cost vs. the benefits?
Provide options
Another good recommendation strategy is to provide the decision-maker with alternative corrective actions. This will increase the probability that the decision-maker will choose one of the alternatives. 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 both corrective actions and system improvements. Although you may not be responsible for analyzing and evaluating safety management system weaknesses for possible areas of improvement, make sure someone is. You'll get the biggest bang for accident investigation buck!
Well, that was a lot of information. Now that you have a better idea what effective recommendations look like, it's time you take the module review quiz.
Take the Review Quiz
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