Initiating an
audit trail for evaluating a safety and health program(s) is a way to test
the effectiveness of written or informal programs. Depending on the amount
of resources and time that one wants to devote, the process can be as simple
as taking several of the incidents you may see listed on a company's annual
OSHA 200 (annual summary of occupational injuries and illnesses), and tracking
back through applicable company reports or programs. By taking this tactic,
one can get a pretty good idea whether an effective safety and health program
has been implemented.
Take the example of two eye injuries that were entered on one company's OSHA 200. The first
step could be pulling the 101's or First Reports of Accidents or Illness for
the two eye injuries. Full evaluation of the reported information first checks
on proper recording, and then evaluates background information as to why the
eye injury occurred. The company had listed the cause of the injury as employee
failure to wear eye protection.
ROOT CAUSE ANALYSIS
This is only the starting point for the audit trail. Now, the real search for root causes,
and the deeper evaluation of the company's programs can begin. Interviews
of the employees revealed that one employee felt that the goggles provided
did not fit. The other employee complained of fogging up of the goggles, as
the reason that the goggles were not being worn at the time of the injury.
An interview with the manager revealed that the manager was reluctant to initiate
the company disciplinary policy for the two employees who were excellent workers.
Typical of most companies, the accident report blamed the victim. The company
had well written safety and health programs, performed record keeping accurately,
and had trained their employees thoroughly. What was missing from their safety
and health program?
IMPACT OF TQM PRINCIPALS ON SAFETY AND HEALTH PROGRAMS
If this company
had applied basic TQM principals, they would have encouraged full evaluation
of the sources of non-conformance (not wearing the goggles), rather than turning
to discipline. If the manager had questioned all of the employees who perform
the job that had resulted in two eye injuries, she would have found that 75%
of the time employees indicated that they did not wear their goggles because
they forgot them in their locker, 10% of the time employees felt that the
goggles did not fit or slipped off, and 15% of the time employees felt that
goggle fogging was a big problem. By addressing each of these issues separately,
incidences of non-conformance could be significantly reduced. The manager
could purchase retainer clips that attached the goggles directly to the hard
hats. Changing the style of goggles could eliminated the problem of fogging of
the lenses. The manager also could purchase an extra supply so that any goggle
damaged by chemicals could be immediately changed as needed.
If only the eye injury cases had been evaluated, a significant reason for not using the goggles
(representing significant risk), would not have been addressed. In other words,
the 75% of the employees who did not wear their goggles because they had left
them in their lockers would not have been addressed.
If the employees
had participated on the accident evaluation, additional input might have been
garnered at the time of the first incident, preventing the second incident.
Also, there was no discussion of the injury and illness entries or near misses
each month during the safety and health committee meeting, indicating a failure
to use the safety and health committee to address real, practical, and soluble
problems in the workplace. Had the safety and health committee addressed the
root causes during their meeting, they might also have been able to address
all of the instances of non-conformance prior to the second injury.
AUDIT TRAIL STEPS
After the first injury the following sequence of events should have taken place:
Perform accident
analysis & appropriate record keeping.
Review accident
report during the safety and health committee meeting for further input,
determine corrective actions.
Determine
whether any near misses had occurred for this job, and if so, why had
they not been reported?
Review job
safety hazard analysis (JSA) for the job in question, revise as necessary.
Re-evaluate
disciplinary/incentive program and how they impact true employee participation
and reporting of near misses - modify if they are disincentives.
Retrain the
employees and managers accordingly.
Perform an
analysis of your conformance with identified critical safety behaviors,
to evaluate the effectiveness of corrective actions.
ADDITIONAL POSITIVE OUTCOMES
If the previous
actions had been completed, a number of positive results could have occurred.
First, by addressing the root causes the manager would have demonstrated her
commitment to preventing eye injuries. Employee participation in the safety
and health committee, accident analysis, job safety hazard analysis, and retraining
of employees, could have heightened employee knowledge and sensitivity to
this critical safety behavior, and increased employee morale and feeling of
being part of a team. As a result of goggle use becoming routine, eye injuries
might have been reduced significantly or eliminated entirely.
Although reviewing
OSHA 200 entries is a good tool for auditing a safety and health program,
it is only one of many tools that can be used. Such an approach takes only
a retroactive look at programs once a problem has occurred. Ideally, a company
should try to be proactive in their approach.
What this audit
approach does, however, is to see if the company's program is a "walking/working"
program, with linkages that interconnect with other parts of the program.
In effect, if an accident or a near miss occurs, this process can be followed
to see if there was the appropriate "ripple" effect. Would the near miss be
reported? Once reported, would the JSA be reviewed, or would employees be
retrained? Making an accident report, because it is expected, but not seeing
evidence of the "ripple" effect, such as changing a JSA or retraining employees
or purchasing new equipment, may be evidence that a safety and health program
is a "paper program" and not a vital working document.
