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 SEVEN: WRITING EFFECTIVE RECOMMENDATIONS
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Introduction Once you have developed solutions that describe engineering and/or management controls to eliminate or reduce injuries/illnesses, the next task it to convince management to make changes. You may perceive corrective actions as immediate needs, but management may see them as planned events. Your challenge is to help them develop informed perceptions. |
Why decision-makers don't respond quickly
When the decision-maker does not act on a recommendation, it's usually because he or she may not have enough information to make a quick judgment. To speed up the process and to improve the approval rate, you must learn to anticipate the questions that the decision-maker will ask in order to sign off on the requested change. This being the case, the more pertinent information included in the presentation, the higher the odds are for approval. Remember, the primary purpose of a recommendation is to persuade. To develop effective recommendations, perform the following key steps 1. Write the problem statement Based on the work you did in the problem-solving phase, you should be able to write a clear statement of the problem. The decision-maker must be able to clearly understand exactly what the problem is. Be sure you describe:- Surface causes Describe the hazardous conditions and related unsafe behaviors you have observed, or that have directly caused an accident. These conditions and behaviors represent the outputs of a safety management system (SMS) that may have somehow failed.
- Root causes Describe the inadequate or missing resources, programs, plans, policies, processes, procedures, rules contributing to the conditions/practices? These represent failures in structure, design or development of the SMS.
Examples of problem statements:
- Condition. “Five ladders in the warehouse are defective.”
- Behavior. “Most employees at the worksite are not reporting injuries to supervisors.”
- System. “The safety training plan does not include lockout/tagout training.”
- Describe the history of previous hazards and system failures. A history of past hazards, behaviors, or accidents indicates an increased probability that a future accident may occur. An established trend is a strong indicator of SMS weaknesses. Of course, the lack of a previous similar condition, incident or accident does not mean it won't negatively impact the company in the future: It could be that you've just been lucky so far. Note: To establish a valid trend, you'll need to analyze data from at least seven points in time: could be seven days, weeks, months, years. It all depends on the kind of data you are analyzing. For instance, if you are trying to establish a trend related to the number of strains and sprains, depending on how often those injuries occur, you might have to look at seven months or seven years.
- Describe how past similar hazards affected direct (budgeted, insured) accident costs. Direct costs of accidents include workers compensation premiums and miscellaneous medical expenses. The employer will pay this (on average) over a number of years in increased workers compensation premiums. It's no different than car insurance...you have an accident, and it's your fault (compensable), your insurance goes up.
- Describe how past similar hazards have affected indirect costs. Indirect costs are immediate costs that come right out of the corporate pocketbook. Indirect costs include additional training, replacement workers, lost production (closing the plant down), increased supervision, etc.
- Make sure they somehow eliminate or at least reduce the hazards and behaviors
- Make sure they somehow improve resources, programs, policies, plans, processes, procedures, practices, rules, forms, documents, reports
- Recommend at least two (ideally three) solutions
- Option 1: What can be done if money it no constraint
- Option 2: What can be done if money is limited but available
- Option 3: What can be done if money is a make/break consideration
- Briefly list low/high cost solutions that eliminate the problem now/soon
- Briefly list low/high cost solutions that reduce the problem now/soon
- Briefly list the advantages and disadvantages of each solution
- Describe the type of accident that might result from inaction. To help educate decision-makers it’s important to describe the type of accident that might result if corrective actions aren’t taken. The accident designations below are useful in describing the types of accidents that might result if hazards are not corrected.
- Struck-by. A person is forcefully struck by an object. The force of contact is provided by the object.
- Struck-against. A person forcefully strikes an object. The person provides the force or energy.
- Contact-by. Contact by a substance or material that, by its very nature, is harmful and causes injury.
- Contact-with. A person comes in contact with a harmful substance or material. The person initiates the contact.
- Caught-on. A person or part of his/her clothing or equipment is caught on an object that is either moving or stationary. This may cause the person to lose his/her balance and fall, be pulled into a machine, or suffer some other harm.
- Caught-in. A person or part of him/her is trapped, or otherwise caught in an opening or enclosure.
- Caught-between. A person is crushed, pinched or otherwise caught between a moving and a stationary object, or between two moving objects.
- Fall-To-surface. A person slips or trips and falls to the surface he/she is standing or walking on.
- Fall-To-below. A person slips or trips and falls to a level below the one he/she was walking or standing on.
- Over-exertion. A person over-extends or strains himself/herself while performing work.
- Bodily reaction. Caused solely from stress imposed by free movement of the body or assumption of a strained or unnatural body position. A leading source of injury.
- Over-exposure. Over a period of time, a person is exposed to harmful energy (noise, heat), lack of energy (cold), or substances (toxic chemicals/atmospheres).
- Describe other natural consequences of management's decision. The natural consequences are those that occur automatically. Inaction might increase the cost of doing business (CODB)due to increased injuries or illness, and lower morale, productivity, quality, and profits. Management action will likely reduce the CODB because employees aren't getting hurt or sick, and morale, productivity, quality and profits remain high.
- Describe the estimated insured and uninsured costs if corrective action not taken. According to the Department of Consumer and Business Services (DCBS), Workers Compensation Division, through the years the average direct cost to close (process) a disabling claim in has roamed around $10,000. DCBS also estimates the average direct cost to close a fatality claim in is around $300,000. According to the latest data (2001) from the National Safety Council, average direct/indirect costs for non-disabling injuries is over $7,000. The direct and indirect costs to employers for disabling injuries is about $29,000. And, the average direct/indirect costs for a workplace fatality is slightly over 1 million dollars!
- Describe the system consequences of inaction. System consequences usually originate outside the organization. Inaction might result in OSHA penalties, increased workers compensation, loss of contracts. Action is likely to result in lower penalties, workers compensation, and a higher probability of winning contracts.
- Estimate the "investment" required for corrective action and SMS improvements. Expressing the "cost" to take corrective action and improvements is better expressed as an "investment" because it helps to communicate the notion that the employer will realize a financial return. The decision-maker may ask you about the return on investment or "ROI". If the investment to correct a hazard is $1,000, and it's likely the potential direct and indirect accident costs to the company may total $29,000 sometime in the foreseeable future (let's say five years), you can find the ROI by dividing the $29,000 by $1,000 to get 29. Next, multiply that result by 100 to arrive at 2,900 percent. Now that's a healthy five-year return!
Next, merely divide that total by 5 to arrive at an estimated annual ROI of over 500 percent! Whoah!
Management may want to know how quickly the investment will be paid back: what the Payback Period is. Just divide $29,000 by 60 months and you come up with $483 per month in potential accident costs. Since the investment is $1,000, the investment will be paid back in a little over two months. After that, we may assume that the corrective actions and improvements are actually saving the company a substantial amount of money. Now that's talking the bottom line! - Describe the risk to the employer if the problem is not solved. Risk is a function of exposure, probability, and severity. The higher the risk, the stronger your argument. Here's the formula for you left-brainers ;-)
- R = f (eps)
- Exposure describes how often the employee is placed in the physical or environmental danger zone (continuous, frequently, occasionally, rarely).
- Probability describes how likely exposure to a danger zone will result in an injury (unlikely, likely, highly likely).
- Severity describes how serious the injury or illness might be (minor, major, fatality).
- Anticipate possible decision-maker objections
Throughout the recommendation, think about what objections the decision-maker might have. Be sure to include counter-arguments to those objections where they most logically apply.
As discussed in OSTN Course 700, employers are motivated to approve your recommendation primarily to meet one of the following safety obligations:
- The Legal Imperative. This describes the employer's legal duty to comply with occupational safety and health standards. When this is the primary motivation, safety is considered just another cost of doing business (CODB) that may drain the corporate budget. Unfortunately, the employer will do only what is required by law...probably not much more. The employer's primary goals are to:
- Comply with OSHA standards
- To "stay out of trouble" with OSHA
- Avoid OSHA penalties
- The Fiscal Imperative. The employer is obligated to corporate stakeholders to operate the business in a financially prudent manner. In the private sector, this means "operating at a profit." In the public sector, this means "operating within budget."
- The Social Imperative. In the best-case situation, the employer feels a strong obligation to each employee, the community, and society in general to support and protect the welfare of all employees...its "corporate family." Safety is perceived as a core corporate value, not open to negotiation.
- The Legal Imperative. This describes the employer's legal duty to comply with occupational safety and health standards. When this is the primary motivation, safety is considered just another cost of doing business (CODB) that may drain the corporate budget. Unfortunately, the employer will do only what is required by law...probably not much more. The employer's primary goals are to:
1) Problem: The guard rail in the warehouse has
deteriorated to a point that it is unable to support any weight on it.
2) History: We had an incident on 6/13/06 where Joe Annon almost
fell down the 10 steps because the guard rail did not support his weight.
He fortunately caught himself before falling. We had a second near miss
incident on 9/18/06 when Jane Doe tripped going up the stairs and grabbed
for the rail which did not support her. Again, fortunately she caught
herself before falling.
3) Options to correct problem:
1. We have attempted to tighten and brace the rail but it continues to work itself loose. We took bids to replace the rail and the bids ranged from a high of $3,200 to a low bid of $1,500. We believe the xyz brand for $2,000 will prove to be the best material for our facility. The disadvantage to the lowest bid of $1,500 was it would not be guaranteed for outside weather conditions. 2. We budgeted "x" for off-site training classes and have secured a source for on-line no-cost training through OSHA that could save "X" dollars that could be applied toward part of the cost of the guard rail.4) Cost/Benefit: ROI. Average cost of a severe injury in is $9,700 which is very possible if one of our employees should fall from the second story of the warehouse to the concrete pad below. The estimated indirect cost is $17,500. Total accident cost is estimated to be $27,200. ROI will be approximately 1,360 percent! Payback Period. I estimate that the probability of an accident occurring within the next two years as a result of this hazard is very high. Therefore, the payback period is based on 24 months. Our cost for corrective action is $2,000 and the pay back period would, therefore, be less than 2 months ($1,133/month.) . |
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