DETERMINING THE DIRECTION OF YOUR PROGRAM: ESTABLISHING POLICY, GOAL AND OBJECTIVES
When you embark on a journey you usually have a reason for going, a destination and a specific plan for reason for going, a destination and a specific plan for reaching your destination. Similarly, when planning a safety and health program, you first decide and put in writing your reason for establishing such a program. This is your policy. Next you decide where you want to end up. This is your goal. Then you map out the path toward your goal, the roads you will take and the vehicles you will use. These are your objectives. In this way you decide the direction of your program.
This chapter will help you begin your journey by explaining how to write and communicate your safety and health policy, and how to set and evaluate your goal and objectives. You will find many examples and worksheets to help you on your way.
The hallmark of every successful safety and health program is top management’s active and aggressive commitment. This commitment, in turn, influences the actions of the company’s managers, supervisors and employees. It ultimately decides the effectiveness of the safety and health program in reducing or eliminating workplace injuries and illnesses.
The company states its commitment through a written and clearly communicated policy for workplace safety and health. This policy stresses the top priority of employee safety and health. The policy statement should be signed by the highest ranking company official on the site.
THE PRIORITY OF SAFETY AND HEALTH
A truly successful company places workplace safety and health ahead of such priorities as production, sales and quality control. If your policy statement makes this clear, it will be easier for employees to choose the correct action when a conflict arises between safety and health and other priorities. Here are some examples of policy statements that convey this belief:
"People are our most important resource. Our company’s principal responsibility is the safety and health of our employee."
"Every employee is entitled to a safe and healthful place in which to work."
"No job is so important is can’t be done in a safe and healthful manner."
"If it is not safe and healthful, we will not do it."
COMMUNICATING YOUR POLICY
To be effective, it is critical that your safety and health policy be communicated to all employees. You communicate your policy by word, action and example.
Communicate by Word. A new employee starts learning about the company’s attitude toward safety and health from day one. By discussing job hazards and providing training in safe work procedures, both one-on-one and in group meetings, you tell the employee that safety and health have a high priority in your company. The supervisor’s continuing emphasis on safety and health reinforces this positive company attitude.
In the smallest of companies, the safety and health policy may be easily explained and understood through spoken statements. However, for all companies, a carefully written policy statement is always recommended. A written statement:
- Clarifies policy,
- Creates consistency and continuity,
- Serves as a checkpoint whenever safety and health appear to conflict with production or other priorities, and
- Supports your supervisors in their enforcement of safety and health rules and safe work practices.
You will want to include the written statement in the information you give new employees. Be sure to post a signed policy statement on employee information bulletin boards. Another eye catching way you can communicate your safety and health policy is by your company letterhead.
For a more detailed look at safety and health policy statements and guidance in writing a complete statement, Appendix 2-1, "Policy Statement Worksheet."
Keep in mind that the written statement is not the policy. It is simply one way of communicating the policy. The real policy is your attitude toward your employees’ safety and health. You demonstrate this attitude by your actions.
Communicate by Action. What you do -- or fail to do -- speaks louder than what you say. Demonstrate your concern for your employees’ safety and health by committing resources to the prevention and control of unsafe or unhealthy work or working conditions, to safe work practices and personal protective equipment (PPE) where needed, and to safety and health training. Whenever you demonstrate a willingness to put safety and health before short-term production goals, your actions forcefully and clearly proclaim your policy.
Communicate by Example. Top management, middle managers and supervisors express the company’s attitude toward workplace safety and health by their daily example. The rules and regulations that you post on bulletin boards and discuss at meetings are useless if management does not follow and enforce them. Set an example: Use PPE properly. Operate equipment safely. Hold supervisors accountable for their safety and health responsibilities. Run your business in a safe and healthful manner.
- Use PPE properly.
- Operate equipment safely.
- Hold supervisors accountable for their safety and health responsibilities.
- Run your business in a safe and healthful manner.
By setting a safety and health policy, you have decided the reason for your journey: to establish an effective safety and health program. Now you must choose your destination, the point toward which your program strives. It is time to identify and set your program goal.
The policy statements discussed above all boil down to the same concept of desiring to provide work and working conditions that are not harmful to your employees. This is in keeping with the stated purpose of the Occupational Safety and Health Act of 9170 [29 U.S.C. 651 et seq.], "to assure so far as possible...safe and healthful working conditions" and to require that each employer "furnish to each of his employees employment and a place of employment which are free from recognized hazard..." and the Act's requirement that each employer "...furnish to each of his employees employment and a place of employment which are free from recognized hazards...."
You may want to consider at least two basic types of goals: numerical and descriptive.
Numerical Goal. Numerical Goals have the advantage of being easy to measure. However, it is difficult to set a numerical goal that is both attainable and comprehensive enough to serve as destination for your journey.
- If you set a goal, for example, of zero hazards at any time, it may be so difficult to reach that you and your employees will become disillusioned long before you have a chance to reach your destination.
- You could set a goal of a certain number of injuries. In doing so, however, you ignore both illnesses and those existing hazards that have not yet resulted in an injury.
- A goal of a certain number of injuries and illnesses may not be feasible. Illnesses often are difficult to recognize until long after employees’ exposure to hazards that could have been prevented or better controlled. And as with the example above, this goal does not address hazards that have not yet resulted in injury or illness.
No numerical goal can be sufficiently inclusive and still attainable. Therefore, OSHA recommends that you adopt a broad, descriptive safety and health goal: A comprehensive program that assesses all existing and known potential hazards of your worksite and prevents or controls these hazards. Such a goal is neither as succinct nor as easily measurable as a numerical goal. But it is attainable. Further, this goal will be helpful in setting objectives. And it should not be difficult to evaluate objectives and program results against this goal.
You may find another way of stating this concept. But OSHA urges you to stay with this basic idea.
You have established the reason behind your journey (policy) and your desired destination (goal). Now you are ready to decide on a travel route. The specific paths you will follow in your journey are your objectives. Setting objectives will make the difference between a haphazard trip and a carefully planned journey. Careful planning is much more likely to get you where you want to be.
Where Are You Now? Before figuring out how to get from point A to point B, it helps to have a clear idea of the location of point A. This may seem absurdly obvious; but most of us, at one time or another, have jumped into a new project or taken off in a new direction without first assessing our present situation. Now is the time to gather as much information as possible about the current conditions at your workplace and about practices that are already a part of your safety and health program.
Is Your Safety and Health Program Complete? At a minimum, your program should reflect these four basic elements:
- Management Leadership and Employee Involvement,
- Worksite Analysis,
- Hazard Prevention and Control, and
- Safety and Health Training.
These four elements are discussed in detail in Chapter I and in several other sources, including;
OSHA, Department of Labor, "Safety and Health Program Management Guidelines" (54 CFR 3908, January 26, 1989); and
OSHA Publication 2209 (Revised 1990), "The OSHA Handbook for Small Businesses."
In the remaining chapters we will focus on how to implement these elements.
Which of the elements are missing from your workplace? Which need improvement? Consider developing objectives that will help you fill the gaps.
Get Everyone Involved. Here is an opportunity to get employees involved. Ask employees and supervisors to help you identify both the successful and unsuccessful parts of your program. (For more detailed suggestions on getting employees involved, see Chapter 5.) Take a look at existing safety and health activities at your workplace. Which ones work well and which do not? Study your records (accidents, injury or illness data, workers' compensation rates) to see what they tell you.
Take a Good Look at Your Physical Surroundings. What obvious physical conditions currently exist that indicate OSHA violations or other hazards? In answering this question, you are beginning to identify your workplaces’ problems and look ahead to the solution. If you come up with an excessive number of physical problems, get these fixed before your attempt to set objectives. Not only are you vulnerable to an OSHA inspection, you are also putting your employees at risk. Further, those safety and health problems that are obvious to you are undoubtedly obvious to your employees. Correct the problems and you demonstrate your interest in their safety and health.
What Must be Done to Get From Here to There.
Now that you know here you stand, what do you need to get done? This is another opportunity to get employees involved in the development of your program. Allow them to participate in setting program objectives. Involvement helps create an atmosphere of acceptance and commitment to the safety and health effort.
Objectives are statements of results or performance. They are short-term, positive steps along the way to your company's goal. Workplace objectives for safety and health are similar to those you set for other business functions such as sales or production. They identify WHAT? WHEN? and HOW MUCH? They do not include a justification for why they should be done; such justification properly belongs in your policy statement. Nor do they contain a description of how they should be accomplished; those details belong in your action plan.
Identify Your Objectives. Anything can become an objective -- from creating a safety and health committee to investigating accidents to developing an orientation program for new employees. You must decide which activities are most important to your program goal and which will help you create an effective overall safety and health program. The objectives you select should be consistent with your basic safety and health policy. And they should be part of the normal business of your company, rather then special projects added on to the normal workload.
Set Your Objectives. Objectives should be based on performance measures, that is, indicators that tell you whether you did or did not perform as expected. When setting objectives, keep the following points in mind:
- Objectives should relate to some part of your overall goal. Example: "Develop and carry out a program to train and license fork lift truck drivers." This objective relates to the part of your goal to ensure that all employees understand the hazards and potential hazards of their work and how to protect themselves and others.
- Objectives should aim at specific areas of performance that can be measured or verified. Example: "Improve safety and health performance next month," is too general an objective to be useful. Better to say, "Make weekly inspections and make certain all hazards found are corrected within 24 hours."
- Objectives should be realistic and attainable, but should still present a significant challenge. Example: "Reduce recordable injuries in the upcoming year by 100 percent." This objective may be unattainable because of the extent and complexity of the measures needed to prevent all injuries. An objective well beyond reach can soon create a defeatist attitude among all those working toward its achievement. On the other hand, "Reduce recordable injuries by 5 percent in the next year," can destroy employee interest by presenting too small a challenge. To set a realistic injury reduction goal, examine your pattern of injury rates for the last 3 years, and set a goal related to improving the best point in that pattern. For example, if you had injury rates of 5.8, 5.6, and 5.7 for the past 3 years, your goal for the next year could be, "Reduce recordable injury rate to 5.0." But always remember that the Occupational Safety and Health Act was passed "to prevent the first accident," and strive to eliminate all injuries and illnesses from your workplace.
- When setting objectives, solicit input from as wide a range of employees as practical. Your ideas already may strongly influence your supervisors. Nonetheless, you will find that safety and health objectives are most effective when you discuss them beforehand with your supervisors or employees. At the least, secure their agreement or cooperation. People who feel they have helped set an objective will be most motivated to achieve that objective.
- Objectives should be understood by all those directly involved. Use terms that have a clear meaning to all concerned supervisors and employees. Leave no doubt about what is to be accomplished. Example: "Determine the cause(s) of all accidents and incidents," may be too abstract to be understood (and therefore accomplished) by those with responsibility. Be clear and specific: "Investigate all accidents and incidents at once to determine all contributing causes, and take corrective action within 24 hours of completing the investigation."
- Objectives need to be achievable with available resources. An objective that requires a large outlay of money or an increase in staff during a budget crunch probably won’t be achieved. Setting such an objective is a waste of time and effort. However, you need not discard this objective. Postpone it. For the present, create an intermediate objective of working to produce the needed resources. Remember, you travel toward your goal one step at a time. The objective you achieve this year may enable you to tackle a larger objective next year.
Write Your Objectives. Put each objective in writing. That gives it more importance. It also helps you track your position at any time and thereby determine how far along you are in accomplishing the assignment.
Spell out in concrete terms what is to be achieved, to what degree, and by when. Be very specific in your wording, and focus on performance. You may also want to include a statement indicating the maximum amount of time or money available to accomplish the objective. Use the guidelines in Appendix 2-2 to help you write well-formulated, workable objectives.
Here are some examples of safety and health program objectives:
- Conduct weekly inspections with emphasis on good housekeeping, proper use of protective equipment, condition of critical parts of equipment and preventive maintenance.
- Determine the cause(s) of any accident within 24 hours.
- Create a written system for documenting all accidents and near-misses and all subsequent investigations and corrective actions.
- Eliminate any hazard(s) identified during accident investigations and weekly planned inspections within 24 hours whenever possible.
- Complete one job safety analysis each month in each department, with follow-up revision of safe work procedures and employee training by the following month.
- Hold and evaluate emergency drills for tornadoes (where appropriate) every 6 months and a joint fire drill/evacuation with local emergency organizations every year.
Keep copies of the written objectives and use them in discussions with your supervisors and employees. Be sure your people understand their assigned responsibilities. Stress that they will beheld accountable for these responsibilities.
Develop an action plan. Actually, at this stage you're already well along in the process of assessing your current situation, identifying safety and health program elements that are either lacking or in need of improvement, and formulating objectives that address your program's needs. The worksheets in Appendix 2-3 and Appendix 2-4 are intended to help you develop an overall design for actions aimed at accomplishing these objectives. Your action plan should address:
- What activities will be undertaken;
- Who has responsibility;
- When the action realistically should be accomplished;
- What resources are needed, for example, people, time, dollars, equipment; and
- How the action will be tracked and evaluated.
The development of your action plan presents another opportunity for employee involvement. Managers and other employees can play an important role in mapping out the details they will be expected to accomplish.
Is It Working?
Review your objectives periodically.
- Are you getting the desired performance from supervisors and employees?
- Are objectives being achieved?
- Are the results moving you toward your goal?
Any program or activity in which you invest time and resources on a continuing basis should prove its worth. If an objective has been achieved, but there continue to be too many injuries, too many close calls, too many unsafe acts, or no improvement in conditions, then different or additional objectives are needed.
Chapter 12 will help you evaluate the effectiveness of these objectives.
Your safety and health program deserves to be carefully thought out and directed. The first step is to write and communicate your safety and health policy. The first step is to write and communicate your safety and health policy. This states your reasons for the program and your commitment to the health and safety of your employees. You express this policy by word (both spoken and written), by action and by example.
The second step is to set and communicate a goal for your program. This is like choosing the destination for a journey. It requires a determination of where you want to be. Your goal can be expressed either numerically or descriptively. There are advantages and difficulties with both, but OSHA has found that a comprehensive and yet attainable goal is most likely to be descriptive. OSHA recommends the following goal:
A comprehensive program to assess all existing hazards and known potential hazards of the workplace and to prevent or control those hazards.
The third step in determining the direction of your safety and health program is to map out your route by setting program objectives. To do this, you first need to know where you are: take a close look at the current state of your safety and health program and your workplace. What more is needed to protect your workers’ safety and health?
The objectives that you formulate, and the steps that you choose to take to accomplish these objectives, should be specific, measurable actions that move you toward your goal. They must be attainable and yet challenging. Use the clearest possible wording, so that your supervisors and employees understand their responsibility and accountability. Once your program is set in motion, periodically review your objectives and the action plan designed to help you implement them. Is everyone performing as expected? Are the results being achieved worth the time and resources being expended? Are you moving closer to your goal?
The success of this effort depends on the commitment of top management and the participation of your workforce. Involve your supervisors and employees in the setting of program objectives and the development of an action plan. The greater their involvement in mapping the route to safety and health, the greater will be their acceptance of the challenges and responsibilities of the journey.