Safety Metrics
Goodhart's law says... "When a measure becomes a target, it ceases to be a good measure." This "law" is often used when denouncing poorly devised safety metrics and/or incentive programs. In most situations where there is a weak/immature Safety Process/SMS, the "law" makes sense; however, this is because, without strong leadership and a functioning Safety Process/SMS, organizations will inevitably and eventually turn "leading indicators" into a "numbers game," just like they turned their lagging indicators into a numbers game to achieve what they defined as "safety success." But there is a simple solution to combat this "law"... VERIFY and VALIDATE our safety metrics and the Safety Process/SMS that produced those metrics!
Let's first understand what I mean by saying, "verify and validate our safety metrics." Merriam-Webster dictionary says:
What does this look like in safety metrics, and how do we use it? Read more ... Add new comment
As you have figured out I am all about having a "safety process" rather than a bunch of "safety programs" and one thing I learn in my Six Sigma days is that a "safety process" MUST function exactly like our quality processes to be as successful. This means we HAVE TO continually "sample" our safety process, just like QC is pulling samples from the manufacturing process. OSHA recently provided a guide "The Use of Metrics in Process Safety Management (PSM) Facilities" to help those who are interested in establishing some "leading indicators" within their safety process. I have also received dozens of e-mails requesting more help with this effort and thought I would share one of my favorite resources on the topic from our friends across the pond - UK's Health and Safety Executive. They have a guide that is a bit more detailed, Developing process safety indicators, A step-by-step guide for chemical and major hazard industries. This guidance is aimed at senior managers and safety professionals within major hazard organizations that wish to develop performance indicators to give improved assurance that major hazard risks are under control. Here are the guide's six basic steps to setting up process indicators measurement system...
RSA Animate - Drive: The surprising truth about what motivates us Of course I am posting this with the slant to "safety incentives", but this video DESTROYS the concept of incentives with the review of some very valid and significant studies. THIS IS A MUST SEE for anyone that already has or is considering starting a "safety incentive" program. When he begins to talk about "motivations" to do things for free... think about the safety profession ALWAYS delivering its message through social media even though we receive NOTHING in return. 1 comment
Recently OSHA has been making waves in the "incentive program" arena and in most cases, rightfully so! But incentive programs DO WORK when they are IMPLEMENTED and MEASURED PROPERLY! The big concern with incentives is that the employer puts too much emphasis on the end results and NOT ON the SAFETY PROCESS that produces the end results. So this article I will offer a way that we can use PEER PRESSURE in a POSITIVE way, rather than the old traditional way where accidents/injuries may get hidden. Last year I wrote about "safety activities" that should make up a safety incentive program; and let me state it again... NO INCENTIVE PROGRAM should be tied entirely to accident rates or number of injuries! Rather we MUST MEASURE the safety process and let the results fall where they may! Here is a little trick that will have your plant's incentive program hopping... Membership Content 2 comments
When lives are at risk, being one percent wrong is all wrong! Every safety, health, or environmental professional deals with situations, which illustrate a broader point. One project recently drove home for me a reminder of how little room there is for error in a field where lives are at risk. This particular project was a complicated asbestos abatement. The renovation work was well underway before testing revealed that fireproofing sprayed on the structural members of the building contained asbestos. Our organization was brought in to do testing, develop an emergency action plan, and perform the necessary industrial hygiene monitoring. 99% right 1%wrong When I failed to persuade the building owner that the mistaken last step was an aberration from the performance through the majority of the project, I understood that 90 percent, or 95 percent, or even 99 percent correct in this case was not good enough. Fortunately, in this instance, the error occurred at a stage in the project where the health or safety of individuals was not jeopardized. This margin for error is not present, however, in many other situations faced by safety, health, or environmental professionals. Other 99% situations to consider:
Accepting a standard of 99% error-free performance would mean that
The examples of situations in our industry where 99% correct is just not good enough are endless. Safety, health, and environmental activities are a perfect fit for a system of total quality management. The consequence of allowing our standards to slip in response to monetary or business pressures is the real possibility of loss of life or limb. And don't be fooled into thinking that standards won't slip. Ask any professional who has been called in to turn a program around how easy it is to fall into the cycle of mediocrity, and how difficult it is to convince people to set their sights higher. Chuck Swindoll explained in his book, "The Finishing Touch," that if goals are not set high, excellent is soon reduced to acceptable, which then slips to adequate, which, before long, settles at mediocre. It is clear, the lesson is all around us. When you step into the arena of safety, health, and environmental activities, the only acceptable goal is 100 percent.
This is the first of several articles I intend to write over the next several months regarding incentive programs and how they can PLAY a SIGNIFICANT and POSITIVE role in improving our true safety performance. Recently OSHA issued an internal memo discussing the use of “safety incentive programs” and this has caused quite a stir in the safety and incentive program community. I have to say up front that there is not much in the OSHA memo that I do not wholeheartedly agree with! But many facilities are going into a panic mode and I am hoping this article will let them see there is HOPE for their incentive program, after all, at least, there is if they follow these simple guidelines… First and foremost, incentive programs NEED to put the “incentive” on SPECIFIC behaviors and actions AND NOT SOLELY ON END RESULTS. What this means is that each facility needs to have a “safety plan” that identifies the necessary safety activities to address the hazards of the business and the previous incident trends. Basically, the facility needs to take a long hard look at their safety activities and determine the top ten that are MOST CRITICAL to the achieving the end results (e.g. OSHA rate goal), but PLEASE do not loose site of process safety! A facility that has a PSM/RMP covered process should have a BALANCED incentive program addressing BOTH personnel safety and process safety. What would this look like? I like to start with the detailed review of my OSHA compliance demands. Have you ever sat down and actually added up all the demands of the OSHA standards that are applicable to your facility. You may be very surprised, as well as this is an EXCELLENT eye opener for management to better understand why EVERYONE NEEDS TO BE ENGAGED IN SAFETY, not just the safety professional. It matters not how many degrees you have, how many certifications you have, or how many years experience you have – there is NO ONE PERSON that can meet all these demands and do it well!!!! When I say a “detailed review” I really mean detailed. Take HAZCOM for example. With the new HAZCOM standard being rolled out, do we have a plan on how we are going to tackle ALL the necessary tasks to get our facility into compliance? We can develop a plan and assign tasks to key management personnel with due dates, such as: 1) who will oversee the Safety Data Sheets and getting all new sheets and cataloging them? 2) who is responsible for container labeling, both fixed containers and portable containers? 3) who is responsible for revising the written HAZCOM program? 4) who is responsible for developing the training program and implementing the new program? Who will oversee the Safety Data Sheets and getting all new sheets and cataloging them? Suggestion: each department manager should be assigned to oversee this activity. They generally have four supervisors working for them and then the supervisors have resources in the way of the hourly personnel. I would provide them with the chemical listing for their department and give them 6 months to get all new Safety Data Sheets. Each month they would have a goal (which plays into the incentive program) to ensure that at least 1/6 of their new Safety Data Sheets in place. Who is responsible for container labeling, both fixed containers and portable containers? Suggestion: Again I turn to Department Managers for leadership in this element of the process. Again I give them six months to get their fixed and portable containers labeling converted over to the new labels. Now some may be thinking that we are “pushing off” our duties onto others – we safety folks hear this quite often! But keep in mind, someone has to identify how many of the specific labels will need to be purchased, then ordered and then dispersed to ensure they are applied to the correct containers. So we are DOING A LOT behind the scenes in order for the Department Managers to meet THEIR safety goals. Who is responsible for revising the written HAZCOM program? Suggestion: This would fall to us and, in reality, we NEED to have this done BEFORE we begin implementing the other phases of this effort. We should not do this within a vacuum, meaning that we should have a process where we DRAFT a written program and allow management and safety committee personnel to comment on the DRAFT. It is then up to us to ensure a COMPLIANT program that CAN BE FULLY IMPLEMENTED at our workplace. The program NEEDS to reflect the responsibilities I am listing in this article. For example, day-to-day responsibility for container labeling (both fixed and portable) falls on Department Managers, as well as managing THEIR DEPARTMENTS Safety Data Sheets. We need to spell this out in the written program so that there is NO CONFUSION as to who is responsible for safety within their departments. Of course, we need to spell out our own responsibilities within the program as well. Who is responsible for developing the training program and implementing the new program? Suggestion: This should fall upon us and other than getting the written program right, this is a major effort on the safety professional’s shoulders. Without a well-written program and a great delivery of safety training – the program is DOOMED for failure! This element also has a shared responsibility with management; we will develop the training and delivery the training, but managers have to ensure their personnel are attending the training. So how does an incentive program fit into all this? Easy, we set goals (with timing) for each of the listed tasks and we PUT AN INCENTIVE on each one to ensure they receive the level of attention we hope they get. Maybe 10% of this year’s incentive funding will go to the “HAZCOM 2012 Plan”. So what do we do with the other 90% of the incentives? Well, I am a BIG BELIEVER in some fundamental safety processes that EVERY FACILITY should be engaged in, regardless of previous safety performance. I call these my “core safety values” that are activities that I feel should be engrained into EVERYTHING we think about when we mention the word “safety”. Here they are: 1) Incident Reporting and Investigation – learning from our mistakes is an ABSOLUTE necessity if we are ever going to achieve an injury-free work place! But we need to shift our focus to the less severe incidents and attack them with the same vigor we would a major injury, fire or release. By this I mean we need to give first aid cases and near misses the same level of respect as the more serious incidents; in fact, I believe that some near misses and first aid cases should receive as much attention as some fatality investigations. We have to get out of the mindset that the more serious the outcome – the more serious the investigation. I am in NO WAY implying that we do not investigate our serious incidents any less, but merely stating that we would do ourselves a great service if we could get in front of these serious incidents with thorough investigations of the less severe incidents. 2) Internal Audit Process – audit-audit-audit, then audit some more! Every single safety activity and program that we claim to be CRITICAL TO SAFETY SUCCESS must be written and implemented with “auditing” in mind. I never really understood this when my brother was beating it into my head in the early 1990’s, but man do I ever know what he was talking about now! There is absolutely no reason to wait and rely on outside auditors to measure our programs and process; we should view the outside auditors as an opportunity for a “fresh set of eyes” and “new and different perspective” to our safety efforts! It is “our house” and “our house rules” and no one should be able to come into “our house” and tell us we have problems! It is our responsibilities to seek out our internal problems and deal with them as a safety family, so when our guest arrive WE KNOW where our progress is and where we need to apply some resources! 3) Inspections – YES auditing and inspecting are two different functions. We can actually AUDIT our INSPECTION program, But it would not make much sense to INSPECT our AUDIT program! Do you recall my earlier mention of doing a detailed review of our OSHA obligations? Well, now we can use all that work we did and put it to good use. There are literally dozens of OSHA-required inspections that must occur monthly and annually. And I am just speaking of the very specific inspections required by specific OSHA standards and not even including all the inspections that take place within a PSM/RMP program. For instance, most of us will have eyewashes and safety showers in our facilities and these devices require routine flushing and inspection. But how many of us have a listing of these devices and their locations and can right NOW – without hesitation- state that 100% of them have been inspected within the last 30 days? Do we have procedures on how these devices are to be inspected and the frequency of these inspections? Let me go out on a limb here and suggest something that I know my OSHA friends will not like one bit… but eyewash and safety showers do NOTHING to prevent accidents, they ONLY mitigate the outcomes of injuries. Don’t get me wrong, these devices can literally be life savers in some work places; but depending on how critical they are, I may not put a lot of emphasis on their inspections. Do not confuse this with THEY MUST BE INSPECTED, but I most likely will NOT make their inspection part of my incentive program! There are items such as respirator inspections, forklift inspections, personal fall arrest system inspections that actually are PREVENTIVE in nature and would garner more consideration from me for inclusion in my incentive program. As a side note and for future discussions, I actually have an audit plan that goes out and audits the “inspection process” to ENSURE the inspections are not getting PENCIL WHIPPED, but I will discuss this in later articles. 4) Housekeeping – one of the most fundamental safety efforts and one of the most overlooked safety efforts is housekeeping. It seems that in the last 20 years, the safety community has resorted to higher tech safety efforts and let good ole housekeeping fall to the side. For example, when Behavior Based Safety became the hot button we let drifted away from our basics and, in turn, housekeeping suffered. I am a firm believer that if we have poor housekeeping in our workplaces, there is no Behavior Based Safety process that will save us from our own hazards! Recently I have seen a resurgence of housekeeping efforts in the form of 5S programs. Although the 5S movement seems to be driven by the quality departments, I am still a fan of the 5S program – IT IS EASILY AUDITABLE and MEASURABLE! 5) Safety Training (these days it’s called EHS training) – Whether you’re old fashioned like me and like doing safety training face-to-face or you have turned the corner and are using more state of the art methods like PureSafety to manage your training on-line, we still have to get it done. And we do not need to be doing it for OSHA, but rather for increased safety! If we think our training is merely to satisfy OSHA then we are MISSING THE BOAT and wasting a heck of a lot of precious time and resources. We need to make our training as effective as we can so that personnel in attendance get something out of it, as well as improve the creditability of the safety process. I had two plant managers that REQUIRED me to revise the safety training presentations each and every year (one way that SAFTENG got famous for my collection of safety photos), so each year I had to “spice up” the presentations and the one thing that I found got the most positive feedback was conducting training as if it was OUR SAFETY PROGRAM and not OSHA’s requirement; using real life examples from our workplace and workforce to drive home the point that this “safety stuff” is for you, me and our families and not some government agency. So with these five basic safety processes, I can put an incentive program into motion and drive the behaviors/participation that is EASILY MEASURED and REPORTED and most importantly… I know will reduce the risk of an injury. Notice that NOWHERE in these five programs have I mentioned OSHA rates, Worker Comp costs, or any other lagging safety performance indicator. We can easily make the shift from lagging to leading indicators using these most primitive safety processes to lead the way. It would be hard to find one safety professional out there who would argue that these five safety activities are the most basic building blocks of a world-class safety process; yet, how many would be able to say they have a written management system that controls how they are carried out, audited and measured? We sort of take them for granted they are so basic; and like I said, we have drifted to seeking out more high-tech safety processes in recent years. These five are JUST THE BEGINNING! They are merely intended to shift the focus on the “safety process” and away from solely looking at and rewarding the lack of injury. I was once told by a very wise plant manager that the “absence of an injury does not make a worker safe… it may just make them lucky”. In other words, when a worker balks at this shift in focus, it says a lot about that workers safety aptitude (this goes for management personnel as well). For years, we have allowed workers to clock in and clock out and as long as they were not injured we considered them “safe”. Heck in my plants we even gave some handsome awards for working “X” years “safely” (e.g. injury free). But the flaw in this mind set was how we defined a “safe worker”! If an employee’s name did not appear on that year’s OSHA Log they were considered a “safe employee”. No one thought to look and see if they had been attending training, or if anyone had audited their actions while working under a hot work permit, or did a housekeeping inspection of their personal work area! I have two safety tales to share with you to demonstrate how IMPORTANT it is that we define what a “safe employee” looks like and sounds like! #1 A worker was doing inventory in a warehouse. She had on all of her required PPE and was even wearing a blaze orange deer hunting vest (VPP site and we wore blaze orange in high forklift traffic areas). A worker was on the other side of the rack and by his unsafe actions (can’t not offer details sorry) he pushed two fifty pound bags off the rack and they landed on the worker on the other side. These bags damn near killed her – she survived but to my knowledge never worked another day. It was her name that went on the OSHA log as the ONLY lost time accident in 4 or 5 years; so it was her that was no longer eligible for the 1-year lease on the Toyota Pick-up truck parked on the turn table at the front gate. Months passed and her accident faded into the landscape of the day-to-day working life at a chemical plant. But winter set in and with that, the Christmas party was the talk of the plant and who was going to win the drawing for the lease on the truck. No one liked my suggestion that we sell raffle tickets for it and set up a trust for “Betty’s” three kids so they could attend college. So the night of the party, those who were not on the OSHA log for the year were standing front and center as the plant manager tumbled the drum with the names. He had his 5 or 6-year-old daughter reach in and grab a slip of paper and with all the fan fare a one-year FREE lease on a Toyota truck deserves, he read off the name of the gentleman who was driving the forklift that caused Betty’s injuries. You could have heard a pin drop in that room of 500+ people and along with that… the credibility of our safety process just took a huge step BACKWARDS! #2 I have had the very misfortune of being involved in several fatality investigations over my years in the chemical industry and more recently as a consultant, but there is one accident that sticks in my mind like it was yesterday. I can still see it, smell it, and hear it like it is happening before me once again and it alone is one of the driving forces that makes me the safety professional I am today. As usual, this accident did not have to happen, much less take a life; but it was the words that our HR Manager spoke during the press conference that made me sick that day. A rather young man, in his late 30’s, had just died from an accident that happened in our plant and the company was in 100% damage control. We have all heard it before, but when it is a friend and a co-worker, the words are a bit more harsh and ring a different tone in our ears. That day they made me sick to my stomach at first, then just downright mad. I nearly lost my job that day for saying what needed to be said and what everyone in that room knew needed to be said! The HR manager had made the comment about how safe good ole “Bill” was and how he had worked “safely” at the plant for more than 18 years. How “Bill” was one of the prized employees at the plant and how he would be so sorely missed. But we knew “Bill” all too well! “Bill” was the guy who never attended safety training because he was “too busy”. “Bill” was the guy who thought safety was just “common sense” and it was a waste of time to attend the required weekly safety talks with his team. “Bill” was the “go to guy” when the production manager needed someone to stay over or work the weekend. “Bill” would do anything for the company; everything but work safely that is. All in all “Bill” was the employee we all want on our team; great friend, always in the right frame of mind, never complained (except about all the safety stuff he never did), etc. Bill died doing the very same act that had nearly killed two workers a couple of years earlier. He had been caught dozens of times committing this unsafe act without as much as a letter in his file. He was not the only one, but he was the leader of the pack when it came to NOT attending safety training or safety talks and never once did he get called out about it. He was the guy that you could almost bet that if you walked into his process you could find him catching a caustic sample with just reading glass that were about to fall off the end of his nose; and yet we called Bill a “safe employee” and a “prized employee” and now “Bill” is dead and his kids orphaned! The OSHA investigation that followed really made me a believer in OSHA, as these two guys were about as good at safety than I had seen within OSHA. And they ate our ass up, spit us out and ate some more!!!! Remember this was a VPP site and one that I had been quite proud of, but after the loss of “Bill” and what I learned from that investigation my whole perspective of what a “safe worker” looks like and sounds like changed forever. The day after OSHA concluded its on-site investigation, the plant manager shutdown the plant (at considerable costs) and scheduled full shift meetings at a local hotel conference. His first order of business was to define what “working safely” really meant. He wanted to workers to define it in their own words, knowing good and well that they were going to be fully on board after “Bill’s” accident. It was not like we did not know what Bill was really like, heck everyone joked “Bill could kill the plant managers kids and still have a job”; although the plant manager did not find it funny when he heard it – he could not really argue, as it was he and the HR manager that turned a blind eye to “Bill’s” lack of safety effort. Through those 24 hours and face time with nearly 800 workers it became clear that we agreed on what a “safe worker” looked like and sounded like and VERY FEW from the group could call themselves safe!!!! It was at that point where the plant manager scrapped the current incentive program and challenged me and the newly formed safety improvement team to come up with a new program that would drive workers to become “safe workers” as we had just defined. So with Bill’s accident in our minds, our safety improvement team reviewed OSHA logs all the way back to when the company had bought the facility and what we found was shocking. With very little evidence from lost or poorly completed reports, it became clear that the facility had NEVER learned from previous incidents. Housekeeping was a common thread, as well as lack of PPE usage. We took a step back and looked at ourselves in the mirror and you guessed it… we still had serious housekeeping problems and PPE issues! By the way, OSHA found the same issues in their investigation/inspection. I know some of you are saying, “how in the heck could this be a VPP Star site?” Easy, we had an incident rate of less than 1.0, strong union support for VPP, and in 30+ years of the company owning the facility no fatalities and only four lost-times! At least up until the loss of “Bill”! The problem we had is the same one so many facilities still have today… we did not know how to define a “safe employee”, so we used what everyone used = OSHA Rates! But it was one OSHA CSHO named “Russ” that pulled me to the side and began to explain to me leading indicators and how if we had been measuring and rewarding the right safety functions rather than the OSHA rate, “Bill” may still be with us. You see “Bill” died doing things the plant had struggled eradicating from its culture for years. He was clearly working unsafe and yet we were rewarding him and all his co-workers for this unsafe work merely because they never got injured!!!! This was in the 1990’s so OSHA did not have a problem with incentive programs back then; heck they sort of encouraged them in a VPP kind of way! But “Russ” showed me firsthand how we could make some minor changes to our current incentive program (based 100% on OSHA rates) and shift the focus to those activities that “Bill” had always brushed off. This would also get some key data in front of the management team so they could respond to those who were not on board. Novel idea… reward those who participate in the safety process and hold accountable those who choose not to participate. It does not take long at all to see who is truly “safe” and those who just talk it. Let the data speak for itself and accept no excuses and in a very short time you will begin to see a shift in work habits and attitudes toward safety. No longer were we going to hand out cash every quarter for just showing up and NOT getting hurt! As the Plant Manager made clear, “You have to earn your safety incentive”! Our program made a BOLD JUMP, primarily because of “Bills” accident, but we removed ALL references to OSHA rates, recordable injuries, etc. from our incentive program. Yes, an employee could actually have an OSHA recordable injury and STILL RECEIVE 100% of their incentive pay if they meet 100% of their safety goals. It may sound crazy at first, but it all fell on my shoulders to ensure we were placing the incentives on the correct behaviors to get our biggest bang for our buck. An incentive program is not designed to make us injury free; it is merely there to entice workers to perform the acts and functions we ask them to do. Just because we have an injury does not mean the program is wrong or a waste of time! Now your incentive program may not need to make such a bold shift, but I do encourage you to begin sprinkling some leading indicators into your program each quarter. Eventually, you will squeeze out the lagging indicators (OSHA rates) and before you know it your program will be based 100% on leading indicators (audits conducted, inspections, training attendance). After all, as safety professionals is this not what we want in the first place?!?!?!!!!! Up next… measuring progress in an incentive program. |
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