The Big Switch: Why You Need to Shift Your Organization From Compliance to Risk

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Over the past 10 years, many in the OSH community began to notice that OSH programs focusing on compliance were not leading to a decrease in the number of serious injuries and fatalities (SIFs). Several factors may have contributed to this including treating all incidents equally, focusing on after-the-fact approaches rather than being proactive, blaming the worker or the use of low-level controls. This led many OSH professionals to reexamine industry thinking and promote the idea that a risk-based approach would lead to improved safety performance.

Pam Walaski, CSP, CHMM, is one of those professionals. As her thinking evolved, she recognized that instituting any new approach may seem daunting, but by making it a gradual process, OSH professionals can utilize risk-based decision making to improve safety and business performance. The best place to start, Walaski says, is for OSH professionals to educate themselves on risk and pass that knowledge on to the rest of their organization.

“In order to lead your organization from compliance to a risk-based approach, you must become an expert on risk,” she says. “Start by reading risk management standards such as the ANSI/ASSE Z690 series, ANSI/ASSE Z590.3 and ANSI/ASSE Z10, then follow that up by finding other professionals involved in risk and systems thinking.”

When identifying individuals with risk-management experience, OSH professionals should look within their own organizations for employees who can help facilitate the transition and act as champions for the cause. These could be individuals who have been involved in OSH risk management in previous positions, or employees in other areas such as marketing, finance or stakeholder relations where risk is already part of operations.

Once the OSH professional has educated themselves on risk and identified like-minded individuals in their organizations, they can begin to transition safety conversations away from compliance and toward more risk-based thinking.

“OSH professionals need to stop relying on compliance with regulations to guide our recommendations,” says Walaski. “We should instead encourage the workforce to think about risk and not compliance, and approach tasks from that perspective.”

This is not to say that compliance should be an afterthought. OSHA requirements are of course important and necessary, but compliance only goes so far in preventing workplace injuries, illnesses and fatalities. A truly effective safety management program examines risks and the adverse outcomes they could have on employees and the organization.

“Help employees identify the risks of the tasks they perform,” she says. “Then you can work with them to reduce risks to an acceptable level by identifying the appropriate controls.”

A key to helping employees identify risks is to shift the focus from lagging to leading indicators. By emphasizing leading indicators, OSH programs can be more proactive and work to enhance a preventative approach to incidents, instead of reacting to them after the fact.

“It’s important to focus away from lagging key performance indicators (KPIs) like the various incident rates commonly used to provide a measure of safety,” Walaski says. “We need to present the idea that days without a lost-time injury is not a measure of workplace safety, and that a strong risk management program is rich with risk-based KPIs.”

Such risk-based KPIs could include measuring conformance rates on controls that are critical to safety, the number of new substitution and engineering controls implemented, the number of management change reviews and closure rates, or the number of new or emerging high-severity/likelihood risks.

As part of the transition from compliance to risk-based decision-making, OSH professionals should identify and promote one leading indicator per year as a way to measure safety performance. By taking this step and reducing the number of times that lagging indicators are discussed, organizations can begin to move the culture toward more risk-based thinking.

Along with focusing on leading indicators, another key to an effective risk-based approach to safety is data analysis. By examining data on incidents, illnesses, injuries and fatalities, OSH professionals can identify precursors of these events. Precursors for SIFs stem from unusual and nonroutine work, from working at heights, or from exposure to hazardous energy, among others. By examining an organization’s data, OSH professionals can determine which work activities pose the highest risk.

“Reviewing data helps OSH professionals familiarize themselves with the work that poses the highest risk,” she says. “They can then begin to build a framework which gives priority to assessing and mitigating the higher risks first.”

Walaski acknowledges that changing long-standing industry practices will not be easy, but that should not prevent OSH professionals from implementing a more risk-based approach.

“We can’t expect to change well-ingrained mind-sets overnight, but we cannot let this challenge overwhelm us,” she explains. “Regardless of an organization’s size, our own risk expertise or how far we have to go, we can all start somewhere and take it a step at a time.”

Walaski will address this topic in Safety 2018 Session 538, “Why You Need to Shift Your Organization From Compliance to Risk,” on Monday, June 4. This session will emphasize the importance of a risk-based approach in improving safety performance, and the steps that OSH professionals can take to lead the transition in their organizations.

Pamela J. Walaski, CSP, CHMM, is director, safety and health for GAI Consultants Inc., where she is responsible for strategic planning, program development, management oversight and direction, and implementation of the firm’s safety and health program for more than 900 employees in more than 25 offices throughout the U.S. Follow her on Twitter @safetypam.

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