Technical Report
American Society of Safety Engineers
Council on Practices and Standards

Staffing Issues and SH&E Professionals

NOTICE: The American Society of Safety Engineers (ASSE) Council on Practices and Standards (CoPS) produced this white paper and set of recommendations. CoPS provides technical insight and expertise to the ASSE’s membership. CoPS also addresses the practice of the safety profession, its specific disciplines and the standards of practice that impact its members and the general public.

CoPS is structured to provide a balanced and sound assessment of matters related to the effectiveness and efficiency of the standards of practice in the Safety, Health and Environmental (SH&E) profession. CoPS consulted with many organizations, entities and governmental agencies to develop this white paper, but it has not been reviewed by any entity other than the ASSE. The contents of this white paper and its recommendations do not represent the views of any organization other than the ASSE. The mention of trade names, companies or commercial products does not constitute a recommendation or endorsement for their use.

The information and materials contained in this publication have been developed from sources believed to be reliable. However, the ASSE accepts no legal responsibility for the correctness or completeness of this material or its application to specific factual situations. By publication of this white paper, the ASSE does not ensure that adherence to these recommendations will protect the safety or health of any persons or preserve property.

Table of Contents

Abstract & Summary Page 3

Introduction & Methodology Page 5

Mission, Purpose & Scope

Appendix A—Fine Paper and Review Page 6

Appendix B—Emery Formula Page 22

Appendix C—Member Comments Page 23

Appendix D—BNA Summary Page 26

ABSTRACT & SUMMARY

The membership of the American Society of Safety Engineers (ASSE) practice specialties has continued to express significant interest in the issue of staffing and Safety, Health and Environmental (SH&E) departments.

The purpose of this white paper was to research the issues involved in evaluating staffing needs in the United States and to compile the results for review by the membership. The second purpose of the white paper was to identify some of the different methods that SH&E professionals use to address these issues. While the white paper is not all-encompassing, it does present a valid “Snapshot in Time” of this issue.

During January 2005, the Council on Practices and Standards (CoPS) sent an electronic mail message to practice specialty members to obtain their feedback and insight about the issues of SH&E staffing. The consensus appeared to be that it is not appropriate or possible to create a one-size-fits-all formula or methodology for staffing since different industries encompass a variety of hazards and exposures. The consensus view appeared to be that the leadership of the company in conjunction with the Human Resources Department and the SH&E Department should decide on proper staff levels based on the results of a quality hazard assessment.

Since the consensus view determined that creating one formula for use in SH&E staffing is neither feasible nor appropriate, the ASSE decided to look at existing materials and member insights. It should be noted that there have been several initiatives in the past to arrive at formulas and strategies for staffing needs. The most noteworthy materials are included as appendices in this paper. In addition to member comments and insights, there are four appendices to this report, which are:

* Appendix A

“Proper Staffing of an Occupational Safety and Health Office” by William T. Fine (1982)

This paper was submitted to the ASSE and printed as an article in Professional Safety in 1982. SH&E professionals have since used the article as a benchmarking tool. The article and a 2004 Business of Safety Committee (BoSC) review of the article are included in this paper as Appendix A.

* Appendix B

“College Campus Staffing Matrix and Formula” by Dr. Robert Emery of the University of Texas (2004)

This matrix and formula were prepared and submitted to the Campus Safety, Health and Environmental Association (CSHEMA) as a study of college campus safety staffing methodologies. A summary of this study and the staffing formula is included in this paper as Appendix B.

· Appendix C

Selected Member Comments

These extensive comments and materials generated much discussion within the different practice specialties. Therefore, it was decided to initiate a second round of “call for comments” to obtain additional information. To gather comments and insight, a solicitation was distributed to a significant number of SH&E professionals to capture anecdotal materials and comments for review. The format of the solicitation allowed the council to analyze some of the different practices used in the profession as well as those used in American business.

The material obtained from these initiatives is noteworthy because it indicates that the ASSE as a professional society must understand that SH&E staffing needs are driven by an organization’s hazards and exposures and not necessarily by the number of employees. These member comments are included in this paper as Appendix C.

* Appendix D

“Environment, Health & Safety Benchmarks for 2004” by the Bureau of National Affairs (BNA).

The BNA conducted an extensive survey of SH&E professionals. This complete survey-based report contains a wealth of insightful and in-depth research, analysis and perspective on critical SH&E topics including:

1. Core duties and responsibilities of SH&E departments and officials.

2. Outsourcing trends and developments in SH&E.

3. Staff levels in SH&E departments.

4. SH&E budgets and expenditures.

5. Salaries of SH&E officials.

6. Newly acquired duties in SH&E as well as relinquished activities.

7. Structure and organization of SH&E departments.

The BNA graciously permitted the ASSE to publish portions of the summary report in this document. Please refer to Appendix D for complete information about the report and for directions on how to obtain the complete summary document.

INTRODUCTION & METHODOLOGY
MISSION, PURPOSE & SCOPE

The council distributed a “Call for Comments” on February 14, 2005 to each practice specialty member with an electronic mail message (e-mail) that asked for comments and materials about staffing and the SH&E profession. Our intent was not to distribute a traditional survey since we were more in need of written responses as opposed to simple “yes” or “no” answers. Members who chose to participate could then click on an attached URL and submit their comments directly online.

Our survey was for the total ASSE practice specialty members who have a valid e-mail address registered with the ASSE. The thirteen practice specialties include:

· Academics Practice Specialty

· Construction Practice Specialty

· Consultants Practice Specialty

· Engineering Practice Specialty

· Environmental Practice Specialty

· Healthcare Practice Specialty

· Industrial Hygiene Practice Specialty

· International Practice Specialty

· Management Practice Specialty

· Mining Practice Specialty

· Public Sector Practice Specialty

· Risk Management/Insurance Practice Specialty

· Transportation Practice Specialty

The solicitation was sent to 8,200 members, and we received a total of 153 responses (2.0%). Out of this number, 49 written comments were submitted. The total comments exceeded over 100 pages in length.

The comments would appear to strongly support the view that it is not appropriate to try to arrive at one formula when calculating SH&E staffing needs. The consensus is strong that staffing needs should be based on a quality hazard assessment and not on a formula based on employee numbers.

The results indicated that companies and organizations use a variety of methods to calculate staffing needs. The most prevalent method is for the Human Resources Department to work with existing SH&E professionals to arrive at appropriate staffing levels.

Appendix A

Proper Staffing of an Occupational Safety and Health Office

by William T. Fine

From Professional Safety (1982)

Due to the absence of research data on this matter, the tables giving weights to various degrees or categories of the elements were compiled empirically based on the judgment and opinions of ten experienced safety professionals by an extensive “trial-and-error” system. Widespread usage and the benefit of many more opinions based on experience will undoubtedly result in further refinements.

Proper staffing of the office responsible for a company’s occupational safety and health program is essential if the office is to perform its mission adequately. But strangely, there are few if any practical guidelines as to what constitutes proper staffing of such an office. Because of the lack of a valid and workable definition of staffing requirements, the safety and health office is often one of the first to be cut when funds become tight or reductions in the work force are necessary. On the other hand, overstaffing is also undesirable.

This article presents a comprehensive guide for staffing an occupational safety and health office, and it takes into account the elements most relevant to requirements for professional personnel. The guide places appropriate weight on each of the principal elements, and by a simple calculation, it specifies the ideal number of qualified technical safety and health personnel required to conduct a reasonably complete occupational safety and health program.

Applicability

This guide is applicable for evaluating the staffing needs of health and safety offices of organizations of all sizes and with all types of activities, from an organization with more than 100,000 employees to a small organization that may require only a part-time safety and health officer. In the latter case, the guide will indicate the actual percentage of time that the part-time safety and health officer should devote to the safety function.

This guide is not simply a device to justify an increase in the size of a safety and health staff. It demonstrates several ways that the required number of personnel in the office can be reduced if the organization will implement some basics of good management.

Scope and Assumptions

The functions that are considered in the guide to constitute a reasonably complete program are listed in Table 1. “Adequate staffing” is the number of persons judged to be required to perform those functions.

The safety office shall be assumed to have a sufficiency of clerical or secretarial personnel to enable safety and health professionals to devote their full time to technical safety and health activities.

No distinction is made between the various categories of safety and health personnel as to whether they are safety engineers, safety managers, safety specialists, industrial hygienists or have other titles. Persons in any of these categories are commonly called upon to perform any or all of the standard safety functions, and they shall be assumed to be technically knowledgeable of safety programming basics and management principles.

Elements to be Considered

The elements to be considered in establishing the required staffing of an office are:

A. Number of employees in the organization.

B. The average degree of hazard to which employees are exposed.

C. The geographical dispersion of employees and facilities.

D. The degree of responsibility the office has for the safety and health of employees at the operating level.

E. The degree of responsibility the office has for developing and establishing policy, procedures and guidelines.

F. The degree of responsibility for safety and health that is assigned to the organization’s line supervisors and managers.

G. Duplication Factor if functions are performed by another office.

H. Additional considerations:

1) Additional duties assigned.

2) Exceptional safety and health situations.

3) Unusual circumstances.

The Formula

The effects of each of the above-named elements on the staffing requirements for the safety office of a particular organization are numerically quantified, and by use of a simple computation, the number of qualified safety and health personnel that should compose an ideally sized staff is determined. Quantification factors for elements A through G above are multiplied, and factors for H are then added to the result. The formula is as follows:


Number of qualified

personnel required

on the = A x B x C x D x E x F x G + H

safety and

health staff

Quantification Criteria

The factors for each of the elements are quantified as shown below:

A. Number of Employees: This is the first consideration. Although identified here as “employees,” the total should include the daily average of all other persons for whose safety and health the office is responsible, such as visitors, contractors, patients in hospitals, clients in offices, etc. The factors for “Numbers of Employees” are given Table 2.

B. Degree of Hazard: The second element to be considered is the degree of hazard or risk to which the employees are subjected or exposed. The factor is a measure of the average degree of risk for all employees. This can be estimated by summations of employees in various job classifications or in the departments that perform work of various hazard degrees. The factor for the average degree of hazard is determined by comparison with examples given in Table 3.

C. Degree of Dispersion: The next consideration is the geographical location of employees whose safety and health are to be protected. The principal distinction is if the working locations are close enough for daily personal contacts and if the office can physically monitor them during a working day, i.e., overnight travel is not required. Factors are given in Table 4.

D. Degree of Responsibility at the Operating Level: While there will usually be a staff or an office at each principal echelon of the organization, the proper size of the staff is directly related to the degree of responsibility the office has for the effectiveness of the safety program at the operating level. Factors are given in Table 5.

It can be noted from the descriptions and factors in Table 5 how an organizational change would cause the category for this element to be changed from “total direct” to “indirect” with an accompanying reduction in the factor, and therefore, a reduction in the number of persons needed on the staff. This could be done by instituting a functional assignment change in the organization, e.g., appointing and training a part-time or collateral duty safety and health officer in each integral group of employees who would be responsible for monitoring safety at the operating level. This would change the category to “indirect” by adding an intervening staff echelon, thus causing the factor to drop from 1.5 to 1.0 and resulting in a lower staffing requirement.

E. Degree of Responsibility for Developing and Establishing Policy and Procedures: There is considerable variance in the degree of responsibility that safety and health offices have for this element. Some offices have total responsibility while others may act only as in intermediate relay point for transferring information. The proper factor can be selected from Table 6, interpolating as appropriate.

F. Degree of Assignment to the Line Organization: The required staffing of an office or staff depends to a substantial extent on this element. Factors are given in Table 7. (Interpolate as appropriate.)

It can be noted here how the factor, and therefore the required staffing of an office, can be reduced by the functional change in the organization of assigning safety and health responsibilities to supervisors and managers. Obviously, such a change will also create a great improvement in the safety and health program.

G. Duplication Factor: In a complex organization of several echelons, it is only necessary that each safety function be performed fully and adequately by the safety office at one of the echelons. For example, if the safety office at the operating level is responsible to perform inspections, investigations, training, etc., the office at higher echelons does not require personnel to duplicate this performance. It may require only sufficient staff to monitor and spot-check performance. Interpolate from Table 8 in accordance with the degree of assigned responsibilities to eliminate personnel requirement that would duplicate performance.

H. Additional Considerations:

1) Adjustment for Additional Duties. This adjustment is for time required of safety and health professionals to perform duties that may or may not be safety-related, but ideally, should be performed by other organizations. Examples include processing claims of employees, administration of the employee disability compensation program, disaster planning, environmental and pollution control, medical functions such as first-aid training and non-occupational disease control, supply functions such as operating issue centers for safety shoes, hardhats and other safety materials, fire marshal duties, driver training and testing, security duties, etc. In each case, the estimated number of managers required annually for such duties should be added to the required staff total.

2) Exceptional Safety and Health Situations. Many organizations have unusually hazardous operations that require additional staff personnel with special qualifications. Examples include extensive chemical or biological laboratories, extensive use or processing of radioactive isotopes and use of lasers and x-rays, explosives handling or processing, etc. Special staffing needed for such operations will depend on the nature and magnitude of the operations, and it must be calculated on an individual-case basis. Add the number of persons required for such duties to the staff.

3) Unusual Circumstances. In any organization, there may be diverse unusual situations that can contribute to the required workload of the staff, such as an exceptionally rapid turnover of employees, a rapidly growing organization or unusually poor employee morale. Such situations could justify recommending additional staffing at least on a temporary basis.

Three examples are given in Illustrations 1, 2, and 3 of computations to determine proper staffing of health and safety offices for three different types of organizations.

Benefits

The use of this staffing guide will indicate whether an office is understaffed or overstaffed based on a quantitative evaluation of the number of professionals required to adequately perform the assigned functions of the office. When the guide indicates that an office is understaffed, it does not mean that the organization should immediately undertake recruitment of additional personnel. It means that the program should be given a careful review to determine which functions are not receiving adequate attention and the actual and potential consequences. Management attention can then be focused directly on consideration of the adequacy of existing performance, the cost of improved performance by augmenting the staff as indicated by the guide and the potential benefits to be derived.

Table 1

Activities of a complete occupational safety and health program.

Internal Management

Organizing and supervising these functions:

A. Development and promulgation of policies, standards, procedures.

B. Inspections and surveys of workplaces and operational areas.

C. Investigations of causes of accidents and occupational illnesses.

D. Training of safety and health personnel and employees.

E. Safety and health education and promotion.

F. Safety and health engineering.

G. Review of hazardous operating procedures.

H. Job safety analyses.

I. Reporting of accidents, injuries and illnesses.

J. Summaries and analyses of causes and factors.

K. Safety and health committee development, promotion and operation.

External Management

Interfacing with these management groups:

A. With all managers to promote management level controls of underlying causes.

B. With purchasing to assure safeguards in specifications and newly acquired items.

C. With personnel to assure safe placement and assignment.

D. With medical to assure physical capabilities and to detect potential health problems.

E. With training to assure employees’ knowledge and skill to work safely.

F. With supply to assure adequate personal protective clothing and equipment.

G. With line managers to promote integration of safety and health considerations into all productive activities.

H. With middle and top management to assure safety and health consideration in all phases from conception through planning, development, operations and disposal.

Table 2

Factors for numbers of employees:

Total Number Total Number

of Employees FACTOR of Employees FACTOR

0-25 0.1 1001-2000 2.0

26-50 0.2 2001-4000 3.0

51-100 0.4 4001-8000 4.0

101-200 0.6 8001-15,000 5.0

201-300 0.8 15,001-30,000 6.0

301-600 1.0 30,001-100,000 7.0

601-1,000 1.5 over 100,000 8.0

Table 3

Factors for degree of hazard:

Examples of

CATEGORY Hazardous Activities FACTOR

Minimal 0.4

Office activity, no power equipment except office machines, no moving machinery, good housekeeping and ample space with few fire or electrical hazards, excellent architecture and structures, good environment, few stairs, good ventilation. No known health hazards.

Low 0.8

Office atmosphere, light power equipment, somewhat crowded conditions, possible minor electrical, fire or structural problems, no known health hazards.

Medium 1.2

Standard wood and metal machine shops, paint shops, non-toxic chemical laboratories, light warehousing and storage, highway transportation, possible minor health problems.

High 2.5

Heavy construction work, excavation, use of hazardous machinery, gases under pressure, toxic chemical laboratories, fire fighting, some radiation hazards, known potential health hazards.

Very High 3.5

Use of highly toxic, sensitive or dangerous chemicals or biological agents, dangerous machinery, high-pressure gases, hazardous transportation activity in air, water or on land.

Critical 4.5

Any activity where one mistake, oversight or moment of inattention is likely to cause a very severe disability or fatality. Examples are deep-sea diving, test flying, handling sensitive explosives or potent biological agents, bomb disposal or defusing.

Table 4

Factors for dispersion of employees:

Number of employees located

where more than one day is

required for visit and return FACTOR

Less than 10% of total employees 1.0

From 10% to 20% 1.2

From 20% to 40% 1.4

From 40% to 60% 1.6

From 60% to 80% 1.8

Table 5

Factors for degree of responsibility for

safety and health at the operating level:

CATEGORY Description of Responsibilities FACTOR

Total direct 1.5

The office has direct contact with first-line supervisors and is fully responsible to monitor and supervise implementation of the program at the operating level.

Indirect 1.0

The office monitors but does not supervise implementation of the program at the operating level. Recommendations are reasonably mandatory. There is one intervening safety staff echelon that is responsible for the program at the operating level.

Partial 0.6

The office makes contacts at the operating level only in an advisory capacity, and recommendations are advisory only. There is one or more intervening staff echelon.

Minimal 0.1

The office has no assigned responsibility for conduct of safety and health activities at the operating level.

Table 6

Factors for degree of responsibility for policy and procedures:

Description of

CATEGORY Degree of Responsibility FACTOR

Complete 1.5

The office is fully responsible for developing and establishing safety policy and procedures.

Shared 1.0

The office shares actively with a higher echelon office the responsibility above.

Partial 0.5

The office receives guidelines, policies and procedures from a higher echelon, adapts or adds detailed implementation instructions and guidance and promulgates same.

Minimal 0.1

The office has no part in developing and establishing policy or procedures.

Table 7

Factors for degree of established assignment to the

line organization of responsibility for safety and health:

Description of

CATEGORY Line Responsibility FACTOR

Full Assignment 0.5

Managers at all levels are assigned responsibility for safety activities, and as an inherent part of their supervisory or management function, are responsible for the occupational safety and health of their subordinates. They are responsible to continuously inspect their areas of jurisdiction and to take corrective action as needed, ensure that employees have and properly use all necessary personal protective clothing and equipment, ensure that equipment and machinery are properly guarded at all times and enforce all appropriate rules and established safe procedures.

Partial 1.0

The responsibilities described above are shared on an equal basis by line supervisors and by the safety and health staff.

Minimal 1.8

The office is responsible for all safety and health activities including those described under “Full Assignment” above.

Table 8

Factors to avoid staffing that would duplicate performance of functions:

If functions (from Table 1) are assigned to be performed by the OSH Office at another echelon:

1) Fully and affecting all personnel, factor is 0.1

2) Fully for 50% of personnel or only 50% of assigned 0.5
functions for all personnel, factor is

3) Not at all, factor is 1.0

EXAMPLE 1: The occupational safety and health office of a district

laboratory of the Food and Drug Administration.

A. Number of Employees: 210. Referring to Table 2, factor is: 0.8

B. Degree of Hazard: (Referring to Table 3)

Averaging the Degree of Hazard:

70 employees in a LOW-hazard environment x 0.8 = 56
100 employees in a MEDIUM-hazard environment x 1.5 = 150
40 employees in a HIGH-hazard environment x 2.5 = 100
306

Average Factor for Degree of Hazard 306 = 1.5

210

C. Dispersion: (Referring to Table 4)

There is no dispersion. All employees work in one city. Factor is: 1.0

D. Degree of Responsibility for Overall Safety and Health at the Operating Level:
(Referring to Table 5)

Category is Total Direct. Factor is: 1.5

E. Degree of Assigned Responsibility for Policy and Procedures of Total Program:

(Referring to Table 6)

Responsibility is between Minimal and Partial. Factor is: 0.5

F. Established Assignment of Responsibility for Employee Safety and Health to Line
Organization: (Referring to Table 7)

Category is Full. Factor is: 0.5

G. Duplication Factor: None

H. Additional Considerations: None

Computation for Required Staffing:

0.8 x 1.5 x 1.0 x 1.5 x 0.5 x 0.5 = .450

Staffing Required: Part-time safety and health officer to perform safety duties 45% of the time.

Computations to determine the safety staff requirement for a small laboratory.

EXAMPLE 2: Naval Ordinance Laboratory

A. Number of Employees: 5,000. Referring to Table 2, factor is: 4.0

B. Degree of Hazard: (Referring to Table 3 and averaging by percentages of employees)

30% of employees in LOW-hazard environment x 0.8 = 24.0
40% of employees in MEDIUM-hazard environment x 1.5 = 60.0
30% of employees in HIGH-hazard environment x 2.5 = 75.0
159.0

Average Degree of Hazard = 159 Factor is: 1.6
100

C. Dispersion: (Referring to Table 4)

Less than 10% of employees are dispersed beyond same-day travel for visit
and return. Factor is: 1.0

D. Degree of Responsibility for Overall Safety at the Operating Level:

(Referring to Table 5)

Safety Office has total direct responsibility. Factor is: 1.5

E. Degree of Assigned Responsibility for Policy and Procedures:

(Referring to Table 6)

Safety office participates, but many policies and procedures are received from
higher headquarters. Interpolate between Shared and Partial. Factor is: 1.1

F. Assignment of Responsibility for Employee Safety and Health to Line Organization:
(Refer to Table 7)

Well-established. Category is Full. Factor is: 0.5

G. Duplication Factor: None

H. Other Considerations:

Administers employee compensation 0.5
Process claims 0.2
Operates safety store for shoes, safety glasses 0.2
0.9

Special Function: Health physics for 2,000 radioactive sources. Four full-time health physicists required.

Computation for required staffing:

(4.0 x 1.6 x 1.0 x 1.5 x 1.1 x 0.5) + (0.9) + (4) = 15.1

Staffing required: 15 full-time professionals.

Computations for determining the safety staff requirement for a large laboratory with hazardous environment.

EXAMPLE 3: The occupational safety and health office of headquarters, Food and

Drug Administration.

A. Total Number of Employees: 9,000. Referring to Table 2, Factor is: 5.0

B. Degree of Hazard: (Referring to Table 3)

50% of employees in offices (LOW hazard) x 0.8 = 40.0
40% in laboratories (MEDIUM hazard) x 1.5 = 60.0
10% in laboratories (HIGH hazard) x 2.5 = 25.0
125.0

Factor is: 1.25

C. Dispersion: Referring to Table 4, 75% of employees located in laboratories
dispersed nationwide requiring overnight travel from the headquarters. Factor is: 1.8

D. Degree of Responsibility for Overall Safety and Health at the Operating Level:
(Referring to Table 5)

Assigned safety officer at each location is responsible
for program. Category for Headquarters Office is Indirect. Factor is: 1.0

E. Degree of Assigned Responsibility for Policy and Procedures:

(Referring to Table 6)

Headquarters OSH Office shares in developing, receives policies and procedures

from higher office, adapts or adds details, promulgates to
laboratories. Category is interpolated between Partial and Shared. Factor is: 0.8

F. Established Assignment of Responsibility for Employee Safety and Health to Line
Organization:

(Referring to Table 7)

Responsibility is well-established. Category is Full. Factor is: 0.5

G. Duplication Factor: 25% of functions are assigned and performed by other echelons
for all employees. Factor is: 0.75

H. Additional Considerations: None

Computation for Required Staffing:

5.0 x 1.25 x 1.8 x 1.0 x 0.8 x 0.5 x 0.75 = 3.40

Staffing Required: 3, preferably 4, safety and health professionals.

Appendix A—Part II

Review of the Fine Staffing Article

ASSE Business of Safety Committee (2003)

The purpose of this letter, which was published in the Management Practice Specialty Newsletter, is to hopefully spur member debate regarding proper staffing levels for SH&E professionals. The Council on Practices and Standards (CoPS) Business of Safety Committee (BoSC) has significant interest in this issue.

The BoSC recently had a conference call, and one of the assignments given was to review an article published in the March 1982 issue of Professional Safety. The article, “Proper Staffing of an Occupational Safety and Health Office,” was written by William T. Fine. The late Mr. Fine was a long-time member of ASSE, and his work in this area was greatly appreciated and respected.

In the years since this article was published, it has been cited on numerous occasions, and it is used to implement SH&E professional hiring practices. Even today, the article is requested on a weekly basis from the society.[1] The members of the BoSC also have great respect for the work of Mr. Fine, and the article is posted on the BoSC website at http://www.asse.org/Fine_article_PS1982.pdf. Members of the BoSC use this article as a resource, and they believe it still has value in addressing the staffing level debate.

One of the expectations from our most recent conference call was to review the Fine article. The BoSC’s review is as follows:

Our basic view is that as we have always known, Mr. Fine presents a nice, neat formula that allows for the quantification of a “difficult-to-quantify” issue. However, we do not believe that the formulas and assumptions made in this article can withstand the scrutiny of today’s environment. From that perspective, we find the article to be of limited benefit.

The work is quite old, we could not locate any supporting data, and the result is that it could not be substantiated. The BoSC did reach the consensus that the article still provides a framework and a good starting point for additional research.

We know from data and research that staffing a safety and health office only represents one portion of the cost of implementing a safety and health program. Some of the research that has been conducted on intervention effectiveness has shown that 15-20% of the total workforce’s available human resource time is spent on implementing activities associated with the safety and health program.

Mr. Fine qualifies his work by stating that it was developed in the absence of research data. This is a good opening statement for his article because while his judgment-based staffing calculations may form a good starting point for more or substantiating research, there are a number of flaws in the work that forced our reviewers to suggest that the formulas be used with caution. The author presents a neat formula that appears easy to use. It seems to quantify some subjective issues, and one might be tempted to use it because it is generally accepted that numbers lend credibility to an argument. However, our reviewers see the formula as providing limited benefit. It may be helpful to justify existing numbers, but it appears dangerous to use this as a means to determine the level of downsizing required.

Now that this work is 21 years old, there should be extensive updating of the considerations before anyone undertakes an evaluation of their own organization. The work is based on the opinions and judgment of only ten experienced safety professionals. This is a very limited resource of ten professionals, and the author does not say any more about the background of these professionals. In what areas are they experienced? From what industries do they come? How much experience do they have? What is the specific expertise of each? What part of the country do they come from? These are questions posed by this reviewer. A mathematical system based on opinions and judgment is already suspect before one even starts reviewing it.

The author makes several statements in the opening paragraphs that are opinion-based, and then he does not justify or substantiate them. “Proper staffing…is essential if the office is to perform its mission adequately.” What is proper staffing? What is the “mission” of a health and safety office? This would have to be defined before any staffing could occur. How would one know how many of each expertise is needed if it is assumed that the mission of a safety and health office is the same for everyone and it is known? The author states that “because of a lack of valid and workable definition staffing requirements, the safety and health office is often the first to be cut when funds become tight or reductions in the work force are necessary.” There is no substantiation of the “first to be cut” issue nor is there any indication that if it were true, the reason is due to a lack of staffing requirement definitions.

While the author seems to make a distinction between safety engineers, safety managers, industrial hygienists, etc., he then washes the distinction away by making the assumption that all of these positions are really just different titles and that any safety and health professional can do all of the necessary health and safety tasks. The staffing formulas make no distinction between the differences either, and this could leave a safety and health staff with an employee who lacks the proper expertise (e.g. this reviewer would not expect a “safety manager” without an engineering degree to approve a 40' scaffold).

While Mr. Fine seems to do a thorough job of defining factors that one might intuitively think would affect staffing levels of a safety and health office, he does not explain enough of the basis for using these factors. No references are cited. Also, Factor A seems to imply that the safety and health office has the responsibility for the safety of others over and above the responsibility that any of us have for the safety of others. This goes against the traditional or historic view that safety and health is a “staff function.” In Factor B, the author proposes to use a degree of risk, but then he relies on subjective judgment to determine it when there are many risk models available that allow for the sound quantification of risk. Factor C implies that for the safety and health office to be effective, it must perform physical monitoring of the worksite. While it may be true and many safety professionals may agree, this is not proven in the literature.

In regards to Table 2, the quantification scale does not appear to have a sound basis. Why does an employee base of 2,000-4,000 (a range of 2,000) have a factor of 3.0, an employee base of 4,000-8,000 (a range of 4,000 employees) only require a factor increase of 1.0 and an employee base of 8,000-15,000 (a range of 7,000 employees) require a factor increase of only 1.0? There may be some assumed quantities of scale here, but they are not explained, justified or substantiated.

Table 3, Factors of Degree of Hazard, offers many subjective or qualitative measures that would make this difficult to judge. However, many of the qualitative descriptors do have quantitative measures to allow sound determination, but the author does not use them (e.g. “excellent architecture and structures,” “good ventilation,” “somewhat crowded,” “possible minor health problems,” etc.).

We spent a significant amount of time reviewing Table 4. This table seems to have the strongest basis with intuitively expected linear increases, but again, the author assumes that regular physical monitoring of the worksite is required for an effective program, and that is not justified by cited literature.

Table 5 seems to addresses the degree to which the safety officer is a line- or staff-function person. It is historically considered that a safety professional is a staff person, and this table seems to give staffing credit for having professionals who are directly responsible at the operating level. This appears to go against traditional line/staff function delineation.

Mr. Fine’s article provides quantification for something often not quantified, and he does provide a basis for consistent application of staffing practices. However, while the formulas, factors and values are not arbitrary, they are based on the judgment and opinions of a very small group of professionals. One should only use these formulas with caution and in conjunction with one’s own experience, judgment and current state of the business climate.

There is not enough sound basis presented to convince this reviewer that the formulas would be of benefit. However, from the vantage point of the BoSC, Mr. Fine presents an excellent starting point for research that would or could substantiate his position and his system.

There are other examples of staffing formulas and guidance documents that we as a profession should review. The U.S. Navy’s Naval Occupational Safety and Health (NAVOSH) Organization and Staffing Guide bases its staffing formulas on sound definition of level of risk and numbers of people served by a safety and health professional. It makes a distinction between health professionals and safety professionals, and it also accounts for specific activities to be performed. While the proportioning factors are better defined and substantiated, it also appears that the Navy formulas provide justifiable staffing based on the foundation needs of risk and the number of people served. This is a model we would like to review in more detail and to assess for use in the private sector.

The BoSC continues to believe that Fine’s article can still be of use, but it should not be used as the definitive document for staffing guidance. We are also aware from data and studies that the role of the safety professional is much larger today and that the breadth of work is much wider and deeper. If the article is to be used for staffing guidance, it is important for end users to be aware of its limitations. The BoSC also recommends that we as a society should move to develop a new formula based on available research and to avoid the Delphi method Fine used with a sample size of only ten participants.







Appendix B
Campus Safety Professionals’ Staffing Methodologies

From previous notices, we have accumulated data from about 75 schools and have developed an EH&S staffing predictor model, which accounts for 80% of the variability of the data reported.

For this project, we have limited ourselves to predictors that were:

· Readily obtainable

· Consistently defined (preferably by a national organization)

· Are relevant to upper management

The model developed to date includes the following parameters:

1. Non-lab net assignable square footage (NASF). (Note that this parameter was derived by obtaining the institution’s total NASF and subtracting the lab NASF.)

2. Lab net assignable square footage.

3. Whether or not the institution has a medical school or veterinary school (1 = yes, 0 = no, obtained from the Association of American Medical Colleges’ (AAMC) and the Association of American Veterinary Medical Colleges’ (AAVMC) listings).

The formula derived to date is:

#FTE = e{0.575(A) + 1.06 * log(lab NASF) + 0.827 * log (non-lab NASF) – 9.25}

(Where A = 0 for no medical or veterinary school, and 1 for either medical or veterinary school or both)

Appendix C

Selected Member Comments and Insights

Comment #1:

“My professional experience includes:

A Metals Company

· 950 employees

· Loss Prevention Administrator (RWL)

· Safety Supervisor

· Security Chief and approximately 12 Security Officers

· Industrial hygiene services provided by corporate

A Coal Gasification Company

· 1,100 employees

· Safety & Loss Prevention Director (RWL)

· Safety Supervisor

· Loss Control Supervisor

· Safety Technician

· Industrial Hygienist (reported to the Environmental Manager in my time)

· Security Supervisor

· Fire Protection Supervisor and Approximately 24 Security and Fire Protection Techs

A Large International Airport with approximately 1,000 employees.

At first I was the first full-time safety officer. Fifteen years later with now nearly 3,000 employees, the SH&E staffing is:

· Safety & Health Manager

· Safety Technician

· Industrial Hygiene Technician

· Workers Compensation/Safety Technician

The staff listed above strictly serves the Occupational Safety and Health Administration (OSHA) aspects for the city employees who maintain the airport facilities. In addition, there is a large staff of airfield safety officers, fire crews and police officers.”

Comment #2:

“One number I have heard bantered about is one SH&E professional for every 200 personnel at a site. This would mean ten people for a site of 2,000. This would include safety inspectors, emergency response leaders and so forth. As for a corporate loading, I think the key is to have top professionals available for every one to two sites, not just for the number of people. The key to providing effective leadership is to ensure that SH&E functions and goals are an integral part of each engineer’s, supervisor’s and employee's job. This may reduce the number of key professionals, but they will need to be more rounded in their training, and they will need to function as subject matter experts (SMEs) and consultants to effectively empower the employees. Given that recommendation, I think there should be one SH&E professional or technical SME for every 50 engineers and supervisors, one practical SME/Occupational Safety & Health Administration (OSHA) expert for every 100-200 operations personnel and one general practitioner for every 200-300 other job functions at a site. In addition, each large manufacturing site should have a minimum of one SH&E resource on a corporate level. Smaller sites could share resources based on complexity.”

Comment #3:

“In construction, a site safety representative should be mandatory for the general contractor and for any subcontractor with more than 20 employees on site at any given time. This is in addition to safety positions already in place within each organization. While performing work on an OCIP project, these criteria were enforced, which made safety just as important as meeting the schedule, if not more so. There were zero fatalities, trailing indicators lower than national average for every standard industrial classification (SIC) on the project. The downside was having 30+ safety reps working vertically on the same project.

To answer the immediate question, I believe that once a construction company has more than 50 full-time employees, a full-time safety professional should be required. But I have seen subcontractors (with five to 20 employees) who have no clue about safety, much less OSHA compliance.”

Comment #4:

(Note: Comment #4 is a compendium of numerous comments made about the general issue of trying to create a formula or standardized methodology to evaluate staffing.)

“We should not oversimplify this issue. The number you are seeking depends upon several factors such as the industry a company is in and the work that they do. This makes the issue very complex. Organizations in which hazard control has been made a part of the line manager's responsibilities need fewer safety professionals. If an organization depends upon consultants and insurance representatives, they will require fewer safety professionals on staff. I believe that if the ASSE proposes a single, one-size-fits-all value, it will not have much credibility.”

“It depends on the industry, risk and on where the company is with their programs (immature and trying to improve or well-developed and sustainable).”

“Refining and other petrochemical facilities may have two to four safety professionals plus one or two industrial hygienists at a 1,000-person site in addition to many techs. At our 650-person site, for example, we have a total of 12 people working full-time in safety and health. We also have a full-time safety committee chairman and a full-time internal audit team leader.”

“At assembly line-type facilities with more fixed hazards, you may not need so many people. For a mature program at a 1,000-person site, perhaps one full-time safety professional and one part-time industrial hygienist will work well, assuming that there is good line support. More may be required on a temporary basis for special projects or initiatives.”

Comment #5:

“The number of SH&E professionals required is a factor of the management accountability and of the safety professionals. If a company or site has a strong safety program in place with top-out management accountability, the SH&E professionals can be used efficiently as advisors, and they can become an integral part of all levels of management. My firm has over 1,200 transient contractor employees at a facility in Texas with two SH&E professionals, a clerk, a trainer and 1,200 employees accountable for safety with incident rates below 0.5. Management was held accountable from the foreman to the site manager for near-misses or unsafe behaviors.

I have worked near sites that required two safety professionals and a nurse (ambulance chasers and cops) with less than 75 employees performing the same task and very high incident rates. Management did not care. My experience has shown me that one SH&E professional and an assistant/clerk for every 300 employees is a good fit.”

Comment #6:

“My insights are based on extensive experience:

· One safety specialist for 40-200 employees

· One emergency response specialist for 100-300 employees

· One industrial hygienist per 100-300 employees

· One process safety coordinator per 100-300 employees

· One safety/industrial hygiene/emergency response manager per 100-500 employees

· For more than 500 employees, add a supervisor.

· For more than 1,000 employees, add two supervisors under the manager.”

Comment #7:

“I have a staff of nine technical professionals, including myself, who act as the in-house consultants to a state agency that collects tolls and operates seven bridges and two tunnels. We have approximately 1,800 total employees in the agency. The Health & Safety Department provides all services for addressing safety, occupational health, environmental and emergency response issues. We have three certified safety professionals (CSPs) and one certified industrial hygienist (CIH). One resource person keeps us all in line. Eight of the other nine all have graduate degrees in environmental, hard sciences or engineering.”

Comment #8:

“I work for a government agency in Ohio. We have about 970 employees, including emergency medical service, a sheriff, engineers, maintenance, courts and all administration. I am presently the only person who is solely dedicated to safety.

While a lot more work could be done if I had help, the level of relative risk is such that it has been difficult to justify additional personnel.

I believe that another safety person would be beneficial to the organization and its employees. Therefore, I would think that in a county government setting, one full-time professional per 400-500 employees would be wise.”

Appendix D

Bureau of National Affairs (BNA) Environment, Health & Safety Benchmarks for 2004


[1] Data provided by the Council on Practices and Standards (CoPS) staff show that, on average, one call per week is received regarding staffing-related issues. The article is provided to those who make staffing-related inquiries.