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by Charlotte A. Garner, CSP
Table of Contents | Chapter 3 Preview | Chapter 5 Preview | Chapter 7 Preview
... The most difficult and most important decisions in respect to objectives are not what to do. They are, first, what to abandon as no longer worthwhile and, second, what to give priority to and what to concentrate on... . These are ... and should be informed judgments. Yet they should be based on a definition of alternatives rather than on opinion and emotion. The decision about what to abandon is by far the most important and the most neglected... . An organization, whatever its objectives, must therefore be able to get rid of yesterday's tasks and thus to free its energies and resources for new and more productive tasks.
--Peter F Drucker
Change Is Ever with Us
As Drucker pointed out in 1969, change is ever with us. Change will always be the wav& of the future. "Opportunities for improvement" (a.k.a. changes) are with us permanently.
There are periods in everyone's experience, both as companies and as people, when we have to make difficult decisions without being certain of a beneficial and productive outcome. These decisions may have concerned financial affairs, downsizing, a major change in employment or plant operations, or advanced technology that appeared to offer opportunities for growth.
Before a company makes those kinds of difficult decisions, management must first carefully assess the depth and scope of the effect of change upon all of the company's operations. The next step is to decide what are the specific remedies, corrections, or eliminations that management will need to make to move the company onto a more productive and profitable track.
After planning the renewal effort, executives, senior staff, managers, and employees embark on the corrected course. This is the same process used in the model SH&E management system: reviewing the outcomes of current processes company-wide, deciding- what, if any, remedies are needed, planning the route through the forest of corrections and adjustments, and moving forward to excellence. The question for you is whether the present company SH&E practices are relevant to the present and the foreseeable future or whether they should be modified, or perhaps even abandoned, to optimize the economic worth of the company and the welfare of the employees.
Keep in mind that, sometimes, radical measures are necessary to accelerate the company's performance and to keep up with competitors who are offering a wider range of options. Markets and competition are worldwide and brutal. Sophisticated competitors and customers are joined with rapid change. These factors exert greater and greater pressures on suppliers to offer quality products at lower prices.
Change and innovation are accelerating with intensity. With these volatile conditions, companies are compelled to examine carefully any and all obsolete procedures that are no longer effectively accomplishing their purposes-those that are not preventing, reducing, or eliminating injuries or illnesses, and that are not cost effective. Some form of redesign or reengineering must rebuild or replace these broken systems. Companies must have effective systems that add to, not decrease, the company's strengths and that allow continuous updating and improvement. Speed, innovation, flexibility, quality, service, and cost are critical to the survival of today's organization.
It is a good idea to benchmark the model SH&E programs of other companies in your company's industry (even your keenest competitors). Look at the cost of injuries and illnesses and of noncompliance and the negative impact of these two nonproductive activities on the economic health of your company. It becomes apparent that the SH&E program and the company will benefit from the ongoing surveillance inherent in and required by the SH&E model management system.
How does the SH&E model management system differ from traditional safety and health programs?
There are requirements in the VPP SH&E model management system that have not been so heavily emphasized in traditional programs. Foremost is that management and employees own and are actively involved in implementing and sustaining the management system. There is no more 'safety is not my job" attitude. The model SH&E system intentionally involves everyone in the company-top management, middle managers, line supervisors, and all employees. It is a structured, organized, systematic management process that addresses the risks of the workplace logically and thoroughly. In Table 1-1, note that in the eight management systems, there is a similarity of characteristics, functions, and operations.
Not only does the model management system help you to identify the problems and challenges existing in the company's current SH&E process, but it offers an organized, workable, time-tested set of guidelines that helps you to resolve the problems and challenges efficiently, proactively, and productively. The primary purpose of this book is to offer this credible and doable process that, once woven into the fabric of the company's culture, will not only identify the deficiencies but also offer the flexibility to accommodate fitting solutions over the long term.
Maybe you have thought that this approach to SH&E management does not compare in depth and scope to the other issues that affect company operations. Not so. From the first two chapters, it is apparent that SH&E has joined with other significant issues that the company must take into account to survive. It is important that the company make every effort to improve this particular system, since the first two chapters show that a dominant factor in the company's profitability is the SH&E management system, which is or can be among the most cost-effective systems in the company. It contributes noticeably to company profitability and to the protection of the employees-two indispensable management responsibilities.
Is this SH&E management system for you?
To help you answer this question, take a closer look at this model SH&E management system. Understand that by adopting this program, the company is in no way obligated to formally participate in OSHA's approval process. It is a strictly voluntary effort.
... we define strategic planning as the 'process by which the guiding members of an organization envision its future and develop the necessary procedures and operations to achieve that future.' This vision of the future state of the organization provides both a direction in which the organization should move and the energy to begin that move... . It involves a belief that aspects of the future can be influenced and changed by what we do now…the strategic planning process does more than plan for the future; it helps an organization to create its future...
--Goodstein, Nolan, and Pfeiffer
Your SH&E program now has a new focus and a defined goal. The focus is to bring the company's SH&E management system up to the standards of 'he VPP criteria. The goal is zero injuries and illnesses. However, the task is complex. Each operation, function, and department has different tasks, work environments, supplies, and equipment. Much of it is the same-for instance, everyone uses pens, pencils, clips, paper, telephones--but much of it differs. Offices do not work with the same equipment as the machine shops or the warehouses. Each function has its own hazards, risks, precautions, and controls.
Now the task is to bring diverse programs and complex operations under one umbrella SH&E system. All top managers and company leaders have a vision of the company's future. Within their assigned areas of work, they have the responsibility to realize that vision. This is true of almost all organizations that plot new courses. There are general similarities; but each will have individual differences.
Why a Strategic Plan?
As the quotation at the beginning of the chapter suggests, strategic planning not only predicts your future, it also helps to create it. You and everyone around you are gifted with creative imaginations. That's how we plan future meetings, how we set goals for ourselves, and how we draw plans for our new home-we are creating our future reality. You can do the same by planning the future state of the SH&E management system.
Strategic planning integrates all of the business functions and cycles. It is for the future; yet maintains the status quo of the present. Strategic planning provides the company with a map for today and tomorrow. The map now requires rerouting to include the tasks necessary to achieve improved processes. The strategic plan is the route to your destination. The challenge is to get there from here.
To successfully follow a new direction and reach the desired destination, the plan must be specific and clear, always keeping track of where it is now and where it is to be in the future. You know the route, the cost, the means of travel, the time frame, and the accommodations when you reach the destination. Now integrate all of these factors into an organized, cohesive action plan.
The number and nature of the complexities will vary from one organization to another, but be assured that challenges will be present to some degree in every organization. To help you get prepared, here are a few challenges to consider.
Challenge 1: Resistance to company-wide change
Any change that affects all of the company operations causes the ground to shift under everyone. Resistance to the change is a common reaction. The current status may not be the most desirable; but change to a different status awakens a fear of the unknown in the people affected. The changemakers must counteract these fears and anxieties by overt and positive actions. Those actions must be defined and planned for the various stakeholders.
Challenge 2: Safety and health issues affect and involve all operations and departments
The criteria get into all operations and departments. This may be new for some of the managers and department heads. The present attitude may be, "Safety is safety's business; not mine." Leaving safety and health issues to the SH&E staff is the normal routine for many companies. Indifference and neglect of the SH&E process exist in many organizations. Lip service at the appropriate times is practiced regularly at the top and middle management levels. Stonewalling among managers and department heads frequently occurs where change of any nature is involved. The new focus pries them out of their comfort zones and threatens their mini-empires. The reactions may extend from cynical indifference to covert sabotage. One of leadership's first tasks is to recognize that these reactions may occur, to have a plan to overcome them, and then to gain the support and commitment that is essential to the system's success.
Challenge 3: It takes time to get there
The gap analyses have finished the estimates of how long it will take to reach VPP quality. The long-term activities will take a few months or a few years. Most companies that participate in the VPP model program take from three to five years getting ready to qualify. The first two years are typically spent changing the paradigms of the managers and the employees so they accept, support, and get involved in the new program.
If this is a voluntary effort and the leadership does not intend to apply for VPP participation, you have the advantage of scheduling implementation of the criteria to fit into the overall company planning. Another advantage of the VPP requirements is that the company is required only to start planning the inclusion of the critical elements and to correct the most hazardous conditions at once. The remaining requirements can be implemented incrementally to fit a company's time and budget schedule. Keep in mind that continual improvement is one of the primary expectations of the VPP criteria, so step-by-step corrections over a period of time are acceptable, just so long as the most hazardous, hurtful gaps are first priority.
In 1992, the Johnson Space Center (JSC) steering committee plotted a four-year plan (see Exhibit 5-1). This is a normal timeline. The application process was originally scheduled for 1994. Due to external circumstances, the plan was set back to 1998. Contingency planning should be a part of the plans to manage unexpected setbacks and obstacles; but a projected timeline of four to five years is realistic.
Challenge 4: The program must have involvement and commitment from all employees
For this new program to succeed, everyone who gets a paycheck must be involved. This means that all employees-top managers, middle managers, senior lead people, and other employees-accept their personal responsibility and accountability for the safety and health program. A strategy is needed to inform and educate all levels of employees in the company and create an awareness of what the SH&E system is about.
Awareness is only the first step toward accepting responsibility and accountability. To do this, there are several options. Communication specialists are available to mount an active publicity campaign to sell VPP to the employees. Based on the size and complexity of company operations, an outside consultant may assist in developing the communications effort, or the in-house public relations department or person can do the job.
An effective self-audit procedure is part of a comprehensive safety and health program and should reduce employee injuries and illnesses, saving the employer costs resulting from absenteeism, workers' compensation and other insurance payments. An effective program may help reduce employee turnover and improve productivity. In terms of the OSH Act, the principal consequence of an effective audit program is a reduction in the number and severity of hazards, leading to a corresponding reduction in citations and penalties in the event of an inspection. A conscientious program should be particularly effective in eliminating high gravity, serious, willful, repeated, and failure to abate violations which carry by far the heaviest penalties... .
--Joseph Dear, Assistant Secretary of Labor (1993-1997)
The results of the SH&E management system evaluation enable you to fine-tune the system processes. The evaluation is a tool to assist you in ensuring the success and stability of your company. Paraphrasing OSHA's words, the comprehensive program audit evaluates the whole set of safety and health management means, methods, and processes, to ensure that they are adequate to protect the workers against the potential hazards at the specific worksite.
T'he self-evaluation is the one VPP program element that OSHA has found generally lacking or misunderstood by sites applying for VPP That is unfortunate, because when your program evaluation is working well, your entire program is constantly improving. The self-evaluation provides both ends of the spectrum for the improvement process-where you are now, and where you want to be. This chapter offers one procedure by which you can conduct a comprehensive program audit.
Review the First Self-Assessment
You and your committee did a lot of work pulling together the information necessary to answer the questions in the assessment. These are relevant documents, especially the performance indicators with which you have been tracking program improvements.
Review the assessment documentation, the findings, the recommendations, and the completions. Aiso review the gap analysis documents to evaluate the closing (or not) of the identified gaps. In the evaluation you are identifying the accomplishments and non-accomplishments in each segment of the SH&E management system. During the assessment, it was mentioned that OSHA has a specific set of guidelines for the site approval evaluation team. These guidelines provide details of how to conduct a complete, all-inclusive self-evaluation. (See Appendix D, "OSHA VPP Site Evaluation Guidelines.")
OSHA VPP evaluators have found that there are three indispensable evaluation tools for judging the effectiveness of the SH&E management system:
Keep in mind that you are looking at the entire management system as one entity. The Shell Chemicals Deer Park Chemical Plant (DPCP) defines their health, safety, and environment (HSE) management system as:
…a structured, documented set of activities designed to ensure and demonstrate that business objectives are met... . The purpose of the HSE Management System is to:
- Use a structured approach to define HSE work processes which achieve and sustain compliance with HSE policies and applicable regulations.
- Assure that HSE risks are managed effectively, enabling continuous improvement of HSE performance.
- Ensure that HSE accountabilities at all levels are well defined, both within the DPCP Plant and between the Plant and other Shell organizations.
Review of Written Programs and Records of Activities
Checking documentation is particularly useful for learning whether the tracking of hazard corrections to completion is effective. It is equally informative in ascertaining the quality of self-inspections, routine hazard analysis, incident investigations, and training. The documentation should indicate the degree to which accountability, disciplinary, and responsibility systems are applied.
Exhibit 7-1 is an extract from Section D, Appendix D, "Narrative Evaluation of Safety and Health Management System," Suggested Form-at for Site@ Annual Submission, Voluntary Protection Program. Policies and Procedures Manual TED 8.41 effective March 25, 2003. This is a summary list of the elements that OSHA expects to find in place during a VPP-approval site evaluation by reviewing validated documentation, by interviews, or by site conditions. Some elements specifically mention "written," "documented," and "tracking." These words imply the necessity for written records to ensure that nothing falls through the cracks; these would include injury rates, management commitment and planning, and safety and health training. Comments, many of which have been extracted from material about each element furnished by Region VI, are included in the following pages.
Along with reviewing each of these elements in your evaluation, you are also required by OSHA record-keeping rules to calculate the company's annual statistics regarding total incident rates, days away/restricted/transferred incident rates, and other statistics. These, too, become a part of the annual self-evaluation since they are another indicator of success or failure in the accident prevention efforts within the company.
Management Leadership and Employee Involvement
Management commitment. The assumption is that top management has committed to tailoring the company's SH&E system after the VPP criteria. Therefore, this section of the self-evaluation report will describe evidence of management's personal involvement. Particularly note in the self-evaluation the status of the company's top level SH&E policy. Are the, employees knowledgeable about it, or do they display uncertainty about what it says and what it means? Record whether it is being taken seriously and, if not, ask of the system, "Why not?" Ensure that there is an explicit, dear description of the methods that management uses to display and demonstrate top-level visible leadership in the SH&E system. Also cite ples of the activities that top-level managers and leaders engage in to clearly demonstrate their commitment. These could be chairing the management-level SH&E committee, always wearing the proper PPE when required, and regularly issuing personal safety messages to all employees.
Employee involvement. Describe the three (or more) activities of the SH&E process in which the employees are involved. Be specific about the nature and types of the employees' decisions regarding hazard assessments, hazard analyses, SH&E training, evaluation activities, or other SH&E areas particular to your companys business or operations.
OSHA does not classify the following as "meaningful involvement":
T'he number or percentage of employees should be stated. This provides you with an estimate of how many employees are involved. The same ones should not be involved constantly. All employees should be involved from time to time, and the evaluation assessment should clearly state this as an improvement goal (if involvement is not happening).
Goals and planning. List the company's goals and the objectives for reaching them. State how the SH&E system fits into the company's overall business cycle in regards to budgeting, resource allocation, training, and so on. Comment on how the employees were notified of the annual goals and objectives, how understanding of them was verified, and what methods were used to achieve them. If the employees were involved in developing the goals and objectives, describe how.
Organization. Describe how the company's SH&E system fits into the overall management organization. This can include a description of the lines of communication with management, reasonable access to top management, and a description of specific activities that include all employees, including contract workers, that are of equal high quality for company and contract workers.