Before we get started, it is critical to understand that the only way your Safety Management System (SMS) will succeed is to make sure the underlying safety culture includes a real long-term serious commitment and tough-caring leadership by management.
This first module will briefly explore commitment and leadership and take a look at some of the other important components that are necessary in an effective safety management system and culture.
Believe it or not, OSHA actually has a pretty good definition for a safety culture. OSHA defines a safety culture as a combination of an organization's safety attitudes, behaviors, beliefs, values, ways of doing things, and other shared characteristics of a particular group of people.
It’s important to understand that, from the employer’s point of view, the company’s safety culture is something to be managed, but if you ask an employee to define the company’s culture, they will likely tell you it’s…
… just the way things are around here.
… just the way things are around here.
The success of your company's SMS depends on the willingness of top management to demonstrate a long term serious commitment to protect every employee from injury and illness on the job.
But how do you get it top management commitment if you don’t already have it? Real commitment doesn't just appear out of thin air. Real commitment values safety.
Management commitment to safety will occur to the extent each manager clearly understands the positive benefits derived from their effort. Understanding the benefits will create a strong desire to do what it takes to improve the company's safety culture.
Managers who understand the positive benefits will more likely invest serious time and money into effective safety management by developing safety policies, programs, plans and procedures. They will also display leadership through effective accountability and recognition of behaviors and results.
Management involvement and commitment can be shown by:
Bottom line: Serious commitment requires serious time and money.
Bottom line: Serious commitment requires serious time and money.
Every day, oil and gas workers, supervisors and managers have many opportunities to communicate and act in ways that demonstrate safety leadership. Unfortunately, these opportunities go unanswered because they are just not seen as real leadership opportunities.
We believe that a company’s leadership is the most important asset it possesses. It’s important that employers and managers understand that the simple expression of tough-caring safety leadership – having high safety standards because you care about the employee - can result in enormous benefits. The ability to perceive leadership opportunities improves the company's potential to succeed.
Tough-caring leaders also assume their workers, at all levels of the organization are good people trying to do the best they can with the skills they have.
Employees, on the other hand, do not always have the physical resources and psychosocial support needed to achieve the kind of results expected of them. Why is that? It is because they are not being provided with adequate physical resources (tools, equipment, machinery, materials, etc.) or the education, training, time, and consequences.
Effective leadership can overcome these challenges by providing the resources and training needed for their workers to excel.
Accountability ranks right at the top with management commitment as a critical ingredient in a company's safety and health management system. Why do we behave the way we do in the workplace? Consequences. Why do we take the unsafe shortcut? Again, consequences play a factor.
Accountability may be thought of as establishing the "obligation to fulfill a task to standard or else." When you are held accountable, your performance is measured against specific criteria and consequences are applied appropriate to the level or quality of performance.
Example: If a builder has built a house for a man and his work is not strong, and if the house he has built falls in and kills the householder, that builder shall be slain. (King Hammurabi of Babylon, 18th Century B.C.)
Example: “The ancient Romans had a tradition: whenever one of their engineers constructed an arch, as the capstone was hoisted into place, the engineer assumed accountability for his work in the most profound way possible: he stood under the arch.” (Michael Armstrong- Former CEO of AT&T, Hughes Electronics, and Comcast)
Management may impose all kinds of safety policies, programs, written plans, directives, rules, training, etc., yet if appropriate application of effective consequences within a culture of accountability does not exist, desired behaviors will not be sustained. If employees do not believe they are going to be held accountable for the decisions they make and the actions they take, you can be sure that any safety effort is ultimately doomed to fail.
Six important elements should be present in an employer safety accountability system:
If you believe there are weaknesses in your employer's accountability system, make sure to document the behaviors and conditions you see in the workplace that may be pointing to accountability system policies, plans, processes, procedures and practices that are inadequate or missing. You can learn more about accountability systems in Courses 700 and 712.
An effective SMS will include stated goals and objectives.
First, it's good to initially develop general goals or "wishes" for your safety culture. Take a look at the following general goals that would be included in the SMS:
Make regular wellsite safety inspections and conduct health monitoring.
Safety objectives are measureable and more specific in terms of results. Here are some examples of operational safety objectives:
Safety policies help to set standards and guidelines for decision-making. They let managers, supervisors and employees make safety decisions with some degree of confidence without having to constantly check with “the boss”. Managers, supervisors and workers know they are making decisions that conform to corporate safety policies.
Below are a number of points that would be good to adopt in your companies safety and health policy.
A wellsite Job Hazard Analysis (JHA) will be conducted on all tasks with a potential safety or health threat.
Every procedure must be a safe procedure. Shortcuts in safe procedures by either foremen or workers must not be tolerated.
If workers observe any wellsite unsafe condition, which may pose a potential threat to their health or safety, they will immediately correct the situation when feasible or inform management.
Management has the responsibility to take adequate proactive precautions, comply with OSHA standards, and assure the safety and health of employees.
Leadership within a company will acknowledge the importance of creating a positive safety culture through employee involvement and effective policies and procedures.
A safety “program” may be thought of as a plan of action to accomplish a safety objective. An effective safety program is designed around the processes, procedures, and practices normally assigned to employees and integrate safety-related decisions and precautions into them. Oil and gas contractors must initiate and maintain such programs as may be necessary to comply with CFR 1926.20. Ref: 1926.20(b) See Module 7 for more information on Programs.
It’s important to understand who is responsible for safety on the oil and gas wellsite construction. According to OSHA, there are four employer roles or categories on a multi-employer wellsite:
Creating employer: The employer that caused a hazardous condition that violates an OSHA standard.
Exposing employer: This is an employer whose own employees are exposed to the hazard.
Correcting employer: This is an employer who is engaged in a common undertaking, on the same wellsite construction as the exposing employer, and is responsible for correcting a hazard. This usually occurs where an employer is given the responsibility of installing and/or maintaining particular safety/health equipment or devices.
Controlling employer: This is an employer who has general supervisory authority over the wellsite construction, including the power to correct safety and health violations itself or require others to correct them. Control can be established by contract or, in the absence of explicit contractual provisions, by the exercise of control in practice.
The controlling contractor assumes all obligations under the standards, whether or not he subcontracts any of the work [29 CFR 1926.16(b)].
To the extent that a subcontractor agrees to perform any part of the contract, he assumes responsibility for complying with the standards with respect to that part [29 CFR 1926.16(c)].
With respect to subcontracted work, the controlling contractor and any subcontractors are deemed to have joint responsibility [29 CFR 1926.16(d)].
Oil and gas companies should designate a person to coordinate, implement, and administer the Safety Management System (SMS). Responsibilities include:
The supervisor’s attitude plays an important part in obtaining or preventing the acceptance of safe and healthful work practices, policies, and procedures. It is the supervisor’s responsibility to identify potential hazards, identify methods to control or eliminate wellsite hazards, ensure workers use safe and healthful work practices, and make sure everyone receives safety and health training to do their work.
Immediate supervisors should review, investigate, and take any necessary and appropriate action on all employee reports of hazards or potential hazards.
Assure employees that they may voice safety and health concerns without fear of reprisal [29 CFR 1903.11(d)].
Inform employees of hazards [29 CFR 1926.21(b), 29 CFR 1926.33, 29 CFR 1926.59, 29 CFR 1926.454, 29 CFR 1926 Subpart Z].
Coordinate hazard communication with other employers on site [29 CFR 1926.59, 29 CFR 1926.65, 29 CFR 1926.652].
It’s important to the overall success of the safety management system that the company makes a commitment to continuous improvement of all aspects of safety and health.
One successful change management technique is to use the Plan-Do-Study-Act (PDSA) Cycle. (Click on the image to the right) It was first developed by Dr. Walter Shewhart, and later applied by W. Edwards Deming, the father of total quality management, to transform the industry of Japan after World War II. He promoted the PDSA Cycle that was partly responsible for Japan's meteoric rise in manufacturing. He believed that statistics hold the key to improving processes, and that management must take responsibility for quality in the workplace because management controls the processes.
The PDSA Cycle contains four important steps:
You can learn more about this important topic in OSHAcademy Course 700, Safety and Health Management, Module 8.
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