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Foundational Elements of a Successful Accident Prevention Program

Addressing Some Common Pitfalls in the Public Sector

by Greg Barlow, CSP, CET
Colorado Intergovernmental Risk Sharing Agency (CIRSA)

Accident prevention cannot be viewed as a “one size fits all” approach. Yet that is exactly what occurs in the public sector too often. Occasionally, there are valid reasons for this, i.e. the lack of full-time loss control and/or risk management professionals to build a comprehensive program. However, most unsuccessful attempts to reduce accidents and overall risk in the workplace stem from factors that are commonly overlooked, ignored, or excused as the cost of doing business.

The goal of this article is not to provide an amazing new approach to accident prevention but rather to provide an eye opener to those that may not fully understand the total concept of accident prevention.

I also hope this article will provide some pointers to allow willing and proactive organizations to get back on track or better their organizational efforts, thus improving all risk/safety management efforts and improving the financial burdens associated with high volumes of accidents, incidents, property damage, litigation, etc.

Basic accident prevention programs follow a simple pattern in that we write policy and procedure, train employees, and expect them to follow the rules, then we experience accidents, make minor or unproven corrections, and may take disciplinary action. This process is usually repeated over and over to no avail. Of course some programs are more involved, some more proactive, but most fall into this continuous rut! Therefore, we must first identify our goals for an overall accident prevention program. Some common examples of obtainable goals are as follows:

  1. Maintain the safety and good health of our employees, citizens, and visitors
  2. Provide objective analysis of the hazards faced within our organization and at our facilities
  3. Weigh all relevant issues, including opinions and facts to develop corrective action options
  4. Choose practical and financially feasible methods for correcting the hazards that lead to accidents

The most important takeaway from those goals is that “compliance” was not mentioned once, and it shouldn’t be! Compliance should be a standard protocol built into any effective operating culture, regardless of what type of compliance is necessary, i.e. EPA, ADA, etc. Compliance should never be the driving force behind efficiency or productivity, or else the program, product, and/or service delivery, will likely fail at some point.

So, how do we implement quality accident prevention programs that meet the aforementioned criteria? The answer is to start with an all-encompassing continual improvement process, commonly called a safety management system.   A safety management system is a series of interrelated and overlapping components and the processes used to support the organization’s efforts and ensure accident prevention success. Those in the business/management genre of our industry will see similarities to the “plan, do, check, act” concept of continual improvement. The components I use are shown in the attached diagram but must also include many sub-components, such as risk financing, purchasing/contract language, safety committees, personnel policy development, engineering (prevention through design), legal, and, most importantly, inter-departmental cooperation, to name a few.Barlow - Infograph2

Knowing that we cannot possibly cover every component and sub-component of a safety management system and how it relates to accident prevention, I have chosen to focus on those 10 pitfalls that most often affect our organizational success. I have provided the occasional example where necessary for concept understanding.

1. Total Management Support & Commitment: City/town managers and/or administrators as well as elected officials must fully understand the concept of accident prevention and must learn and understand the hazardous nature of the work their employees are doing. This is paramount to better address their level of support and those decisions that are made, which may affect the ability of the employees to work safely. Politics should be taken out of this process as there is no room for it when it comes to human life. What did he just say?? Remove the politics…impossible! Unfortunately, as you were reading that sentence, if you had a similar thought going through your mind, well, then you are completely missing the point. We will never eliminate politics. We can easily remove politics from any decision that affects the safety and well-being of our employees, visitors, and our citizens.

Example – A streets department must shut down one lane of a roadway for several hours a couple times a month for standard maintenance on a structure. This causes unfortunate but necessary delays to patrons traveling the roadway and complaints are filed. The department is told to speed up the project no matter what…..an all too common occurrence! What is not understood in this case is that the work requires a certain minimum of cones, signs, possibly flaggers, etc. all which are necessary and required by federal law, to help protect the workers. Requiring them to speed up the project can result in removal of much-needed protective equipment, injuries, possible death, and potential violations of the law that could materialize should any litigation occur.

Resulting Problem – Employees know where these types of decisions stem and when these decisions reduce their level of safety. Morale is lowered significantly, and a “lack-of” safety precedent is set. A much better approach would be to evaluate the work process to make it as safe and efficient as possible within the boundaries of the law, while also notifying the citizens that this delay is occasionally unavoidable to protect the employees and the citizens traveling the roadway. Those in managerial and administrative positions must be well versed on these issues and be willing to respectfully and politely, stand firm with complainants who do not understand the risks.

Long-Term Success Strategies – Managers and/or administrators should write “safety policy statements” that support the organization’s efforts and sign them, providing one copy to every newly- hired and existing employee. Consideration should be given to developing a 5-10 minute video describing your support of all safety efforts. Several times per year, make unannounced visits to job sites, facilities, and treatment plants, as well as safety committee meetings, and don’t forget to wear your PPE! These efforts provide the “talk the talk and walk the walk” validation that many lower-level employees use as a gauge for the true support received by their management teams at all levels.

2. Safety Programs, Policies, & Procedures: Those of us in the safety/risk genre have a tendency to write lengthy programs that would be difficult for anyone to read and maintain consistent competency, given all the rules and requirements, forms, etc. Sometimes these detailed programs are necessary, but consideration should be given to limiting any safety policy to a maximum of five pages.

Example – I have been subject to and, unfortunately, have written individual safety programs, such as confined space, that are 20 pages or more. The justification is usually that detailed and extensive explanations must be given to those doing the work.

Resulting Problem – This “more is better” approach almost always results in employees that do not read the programs, read them only when forced to read them, and/or don’t use them as the intended “safety tool” they represent. Remember, safety programs must be functional to be effective, and if the employee cannot easily understand or find the data they need, it will not get used.

Long-Term Success Strategies – The question that should be asked is, “what do the employees absolutely need to know in order to do the job correctly, efficiently, and safely?” Furthermore, “how much unnecessary background, technical, statistical, and repeated information can I remove to make this plan more efficient?” We recommend the evaluation of all policies and programs and recommend considering moving towards JSAs (Job Safety Analysis) that are shorter, more concise documents. These can be supplemented with short video JSAs as well. Revise, shorten, and/or eliminate multiple forms and especially duplicate information in safety programs. Move towards checklist-based forms that accompany the JSAs, while accomplishing safety goals and serving as “training tools” for new hires and refresher training for experienced employees.

3. Multiple Job Task Methods: Every organization has hundreds, if not thousands, of individual job tasks that have to be performed by employees. These tasks should be explained and demonstrated to employees by competent supervision before allowing the employee to perform the work. Employees should also be required to show competency in said tasks during hands-on training before performing the work. Unfortunately, the normal course of action involves supervision, assuming the employee knows how to do the job task. The employee compounds this assumed trust by not asking many questions or just agreeing to whatever they hear in order to make a good impression.

Example – A parks and recreation department enters the spring growing season with weed eaters tuned and ready to go. Their primary task each week will be addressing the fast-growing grass around and within the medians of the recreation center parking lot. Full-time and seasonal staff is provided basic instructions, watch a safety video, and sent out to tame the weeds. Staff must constantly dodge vehicular traffic, pedestrians, and flying debris while preventing damage to vehicles, recreation center windows, and injury to patrons.

Resulting problem – Everyone has “their” way of doing a task. Case in point, experienced workers may either work safer or take more chances depending on their attitude. Newer/younger employees will do whatever they learned to do but usually with a twist of speed in order to hurry up and get finished. This results in multiple methods for completing the exact same task, and anytime multiple methods are allowed to continuously be used in the workplace, this increases the probability of accidents/injuries occurring.

Long-Term Success Strategies – Having many methods doesn’t mean all methods are wrong. What it does mean is the organization has unknowingly created a greater potential for exposures. Therefore, the best approach is to bring in everyone who performs that singular task. List the steps of the operation generically (this is also the process for developing JSAs), evaluate each step, listing the hazards and potential outcomes of said hazards, and then develop the safety mechanisms that will prevent those hazards from causing harm or reduce them to their lowest level of harm. The end results are one or two methods that everyone learns and follows, creating consistency in safety efforts and a reduction in potential injuries, property damage, and legal issues. It has been shown that by using this or a similar methodology, production and efficiency will also increase.

4. Contractors: Utilizing contractors for various tasks is not only a great cost savings initiative at times, but it can be a great example of risk transfer, thus taking the hazards away from your employees. Despite the private industry’s obligation to follow OSHA requirements, when contractors perform work for cities, towns, special districts, etc., the safety procedures have a tendency to fall by the wayside due to financial constraints realized while trying to become the “low bidder” and win the contractual award. Unfortunately, all safety/risk professionals in the public sector know this, and, more often than not, it results in the contractor’s safety budget being the first line item eliminated or significantly reduced.

Resulting Problem – When contractors work unsafely on our entities’ projects, our employees are exposed (physically and/or visually) to these unsafe acts on a daily basis. Sometimes our employees are placed in harm’s way as they must work in the same areas the contractors are working.   Our employees see these contracted employees being allowed to work unsafely and even though our organizations’ employees may be told to follow the rules, they know it is only a matter of time, a particular project deadline, or a little political pressure before they are required to work unsafely to get the job done. Not only does this increase the probability of accidents and injuries to the contracted personnel and our employees, but it increases the potential for reputation dampening to our entity should something go wrong, as we all know these issues seem to make it to the media outlets instantly when a problem arises.

Long-Term Success Strategies – Eliminate the current trend of always selecting the low bidder. Instead, implement a process where the safety records, OSHA penalties, experience modification rates, as well as on-time completion rates, are evaluated for each contractor. This will help to guarantee that all the money saved by selecting the lowest bidder is not lost due to project delays, injuries, and sometimes incompetence. Inversely, when quality, competent, and expedient contractors are found, develop longer term contractual awards or other legal purchasing-related methodologies that allow them to continue to perform work instead of eliminating them if they aren’t the lowest bidder. Most state laws allow for a combination of low bidder, along with an evaluation of the contractors’ performance, and ability to conduct the work according to the organization’s needs and policies.

5. Prevention Through Design: One of the most often overlooked areas is that of facility design reviews and the equipment selection process. Most of the time, management teams, without the input from those employees most affected, make the decisions of what type of design to implement and/or what type of equipment is purchased. All too often this decision is the byproduct of high quality sales pitches and/or crafty design firms, whose primary goal is improving their profit margin.

Resulting Problem – When lower-level employees (those end users of the system, process, facility, or equipment) are left out of the loop during the design and/or selection process, areas are guaranteed to be missed, such as maintenance access issues, employee exposure, and other bodily safety issues, not to mention the inclusion of unnecessary and/or costly long-term replacement, retrofit, or maintenance concerns.

Long-Term Success Strategies – It is recognized that every employee cannot be involved in the design and selection process. However, a simple, stepped approach can be utilized that allows the initial discussion about the new design or new equipment selection to be provided to each layer within the organizational structure for feedback, i.e. pros and cons of the existing equipment or facility and desired elements for future inclusion. This information can then be turned over to the engineering department and/or outside design firm or vendor for inclusion in the first proposal and/or the first design review, usually occurring at 15% or 30%. Not everyone will obtain their “wish list,” nor will every potential hazard be eliminated. Yet, this methodology has proven for decades to prevent many injuries and property damage and significantly reduces future retrofits and the subsequent associated costs.

6. Employee Incentive vs. Discipline: One of the most controversial elements of any successful program is discipline vs. incentive. These two are a cohesive unit that must be handled equally and consistently. Current economies have resulted in a trend of little to no raises for our employees. This, as we know, is always an ebb and flow cycle, and better times will return. Regardless, employers still try to incentivize employees in other ways, and this is a great concept when done correctly. However, the best incentive program in the world is always offset by the failure of an organization to take appropriate disciplinary action and ultimately remove significant and/or disruptive burdens to the organization.

Resulting Problem – Every organization has their “problem children.” These are folks that just don’t get the job done efficiently, have repeat accidents, have an openly bad or even disgruntled attitude, disobey management whenever possible, etc. We all know this list could go on forever. Yet, these individuals almost always seem to be long-term employees. For reasons unknown to anyone, the troubled few remain a thorn in our operations. Excuses for not disciplining or dismissing these individuals range from the lack of previous documentation of violations to threats of discrimination and many other factors.

None of these factors are the true culprit behind the problem. The real problem is the supervisors that have pushed these employees through with positive evaluations and overlooked disobediences. Sometimes these “bad apples” have even been promoted just to get them out of a particular department! The answer often given for these actions is, “He/she is a hard worker usually,” or “I don’t want to hurt their feelings,” or the worst of all, “Who else will hire them if we let them go?” The reality is that these excuses, although well-intentioned toward our fellow humans, are a curse to the organization and to the employees that must work with and around these troubled souls. The “good” employees may then suffer themselves with annoyance, anxiety, a lack of understanding of why nothing gets done, and ultimate resentment towards the management teams that allows the “rotten fruit” to remain a part of the workforce. This is a guaranteed “deal breaker” with many employees, no matter how much the other elements are incentivized…good employees will never forget when they are required to do more, work harder, follow all the rules, while a few are allowed to get away with, seemingly, whatever they want!

Long-Term Strategies – This is one of the hardest issues to correct with existing problems that have not been resolved. Quality discussions with legal and human resources can put action plans in place. Simple policy changes that affect all new hires can help to eliminate the future conditions that lead to the problem. A change in the performance evaluation process and/or scoring also can help. Ultimately, the most proactive solution for the organization, and possibly even the troubled employee, is an open discussion with all the important players and the troubled employee. This discussion can be stepped, starting with the employee and the supervisor, then to HR, etc. The previous concerns can then be outlined along with why actions weren’t taken in the past. Depending on the organizations policies, outside counseling may be offered, as well as numerous other employee assistance programs that are available and beneficial. In the end, an “employee/performance improvement plan” must be implemented with specific goals and actions, along with the behaviors that will not be tolerated moving forward. Timelines must be established and all components followed through to the letter of the plan. This strategy, while uncomfortable, will change behaviors and result in long-term success, while showing high-quality employees that action is being taken.

7. Training Programs – When it comes to safety and health training, most organizations follow the antiquated approach of only sending employees to and/or holding classroom presentations. Other methods include watching DVDs or completing online modules. While these elements are viable methods of “information flow,” this is neither functional nor absorbable training, at least not for very long, and definitely not as a singular process for training employees. Employees do gain some new knowledge and/or refresher information while in class, completing online modules, or watching DVDs, so they should be used in moderation. They receive certificates of completion in most cases that show they were trained; their names are prominently displayed on “sign-in” sheets the organization can use for documentation for audits, other insurance purposes, and the occasional and dreaded legal discussion. In many cases, the supervision/management team does not attend the training they require their employees to attend, when in fact they usually need the same and/or more training on the topic.

Resulting Problem – When our training stops with these types of sessions, information is not well- retained, especially when it is information such as safety rules, which most employees find boring and intrusive. This leads to the majority of the employees falling back into the exact same patterns of potentially unsafe operations the training was designed and delivered to prevent. Additionally, when supervision/management fail to attend the same courses they require their employees to attend, important issues are missed, morale is decreased, and a definitive, non-arguable precedent is set in that employees now know how important the training really is to their supervision. The standard excuses of, “I’ve got another meeting,” or “I’ve been to that training a dozen times,” etc. does not fly with employees!

Long-Term Success Strategies – Each of the training options should be immediately followed up with hands-on training efforts that are lead by supervision, not safety staff. This should be conducted as soon after the classroom session as possible. Furthermore, everyday job tasks can be used to display lessons learned from training by taking 10-15 minutes a few times a month to cover an important aspect. This should be done at all levels within the supervisory chain. More proactive programs should also have employees lead occasional hands-on training sessions, which sometimes hold significant weight with their co-workers. Organizations with full or part-time safety staff should try getting creative with training activities, such as creating “mock” hazard scenarios and having employees solve the problems, simulate equipment failures, etc. Quality training will simulate, to the best availability, the actual failure events that occur with the job task, thus allowing employees to work through those problems in a controlled and safe environment. The time/money spent on training activities will definitively offset the hard and soft dollar costs of real accidents. Regarding supervision/management attendance, the short answer is that despite your rank, title, number of years on the job, and/or perception of need, with regard to the training, if you are the boss, you better attend and participate in the training program…that is, if you want true, long-term success, trusting employees and “buy-in” to your program efforts.

8. Accident Investigations: One of the most productive elements of a safety management system is the accident, incident, and near-miss investigation process. Some like to trade the word “investigation” for “analysis” to help eliminate any negative connotation to the process. Regardless, quality investigations will provide organizations willing to pay attention with a gap analysis, failures, learning events, and options for long-term corrective actions and elimination of some hazards to the workforce. Unfortunately, organizations commonly find the first one or two items that appear to have caused the accident and look no further for the real cause(s) or underlying root causes.

Resulting Problem – When all “root” causes are not identified, the accident sequence likely still exists and will occur again, albeit along a different path than the first time. Those agencies that have continuous repeat accidents may even make statements, such as “I thought we addressed that hazard,” only to find out later there were multiple hazards and/or root causes that should have been addressed. Ultimately, the lack of reduction or elimination of these hazards contributes to more frequent accidents and higher insurance contributions (premiums) potentially through higher claim counts/costs, thus reducing departmental and divisional budget availability.

Long-Term Success Strategies – Investigate everything completely and thoroughly. This includes the often-overlooked or ignored near-misses. Provide quality investigation training to employees and supervisory staff to ensure everyone is on the same page. Do not settle for guessing or opinions about what might have happened but rather do the research, re-create events, talk to experts, and determine actionable items that allow for the development of appropriate corrective actions. Most importantly, relay the information up the chain of command so a clear understanding is provided with regard to why the event occurred and what it will take to solve it, both short-term and long-term. Should you be within the upper management chain of command, pay attention to the investigative findings. Your decisions, as stated in item # 1, can significantly affect the safety of your employees and the cost to your organization.

9. Corrective Actions: While technically a part of the accident investigation process from a safety management standpoint, I prefer to separate the two. My justification lies in the importance of this element. The investigation will provide the answers needed to solve the problem. The corrective action phase provides the methodology to implement those solutions. While a failure to implement appropriate corrective actions would create significant ongoing problems, this phase does not lead to any other resulting problems when corrective actions are administered. The long term success lies in what most safety professionals call, the “Decision Hierarchy” and is shown in the attached diagram. The six primary control methods are arranged from most effective to least effective. “Transfer” of risk is often added into the substitution category or even added as a category all by itself.Barlow - Infograph

10. Measurement and Correlation: This category is explained quite easily but can become comprehensive in nature, depending on the type of metrics developed and tracked. Good data can always assist in the safety management systems continual improvement process. For example, sometimes high quality, very proactive organizations get so involved in the routine of a safety management system, they may miss the less significant details that cause their accidents. Think of the measurement process as a “quality control” function. It may allow an organization to readily recognize a gap or flaw that was previously missed and this allows redirection of resources toward that problem while maintaining an acceptable level of resources in other areas that have become self-sufficient. The correlation component will allow the occasional shifting necessary to keep all safety management system elements in balance and allow each component to continue to benefit each other.

These 10 foundational elements by no means address the specificity of an individual organization, and any organization’s individual “pitfalls” could deviate slightly, as well as gain 10 more. I am very confident that most public entities face the majority, if not all, of these aforementioned issues. Some may also argue that I have left off one of the most important foundational elements, that being employee attitude and resulting behaviors or “behavior based” safety efforts. My decision to leave that discussion out is the same reason for leaving out the multitude of other sub-components of a safety management system. The justification is simply that if the previously mentioned 10 elements are used as a focal point, the behaviors of employees will start to move toward a more positive outlook on their organization’s safety efforts, as well as their belief in said efforts and, most importantly, trust in their management teams.

When we gain and maintain trust from our employees, we have reached a level of success that will build our safety culture, ensure the fewest accidents and property damage claims possible, and help guarantee the long-term success of our organization’s reputation and financial prosperity.

Finally, the most important element of all is the willingness of supervision and management to get involved proactively, understand our lowest-level employee issues, and be willing to change our behaviors/actions for the greater good of the organization. This change may be necessary, even when we, as the management team, don’t want to admit that we may actually have been the problem all along, or at least a significant contributor.

True leaders evaluate themselves more harshly than they would ever evaluate their employees. A true leader asks their employees what they need to improve upon and never holds a grudge but rather recognizes their personal/management-related flaws and corrects them.

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