All employees are openly encouraged to report hazards when they are discovered. In many organizations, this is a basic tenet and often included in the duties and responsibilities of each employee. Some organizations take this one step further and utilize worksite safety observations as an activity to provide meaningful employee involvement in the safety program. This is commendable and even encouraged but certain requirements must be met in order to provide a beneficial experience for both the company and the employees. First, the employees must have proper safety observer training. Second, the employee must have a way in which to report the findings efficiently and effectively, preferably also having the work-stop authority to engage with the observed party and work to provide a safe outcome.
According to OSHA , a "competent person" is defined as "one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them". I would say that each person tasked with performing worksite safety observations must meet this definition to some extent. To become a competent person, an employee can obtain the capability through a combination of training and experience. The authorization must be established with the company and the employee and should also involve tools and techniques to positively intercede.
This leads me to a recent conversation I had with a safety director on this very subject. Here is the gist of the exchange (Safety Director = SD; Myself = CU):
Upon looking at the data, we saw that the PPE category comprised of over 35% of the observations. We also found that about 50% of all inspections documented no hazards.
We went back to the data and saw that there were very few observations in these areas. In addition, the checklist used for these critical areas were insufficient and didn’t really incorporate lessons learned and contributing factors discovered during the injury assessment process.
We both agreed that the current way of doing things could definitely improve. There was a broad assumption that the training provided was sufficient and met the safety observer training objective yet the data did not support the reality. I then began to explain how we did this in the military. When I served in the United States Navy, we used a Personnel Qualification System (PQS) program. The Naval Education and Command describes the program as follows:
The PQS is a qualification system for everyone where certification of a minimum level of competency is required prior to qualifying to perform specific duties. A PQS is a compilation of the minimum knowledge and skills that an individual must demonstrate in order to qualify to stand watches or perform other specific routine duties necessary for the safety, security or proper operation of a ship, aircraft or support system. The objective of PQS is to standardize and facilitate these qualifications.
Although the wording was a bit odd and we weren’t on a ship, we did feel the concept was sound and could be used. We felt that there were two primary components to this process. The first was that of knowledge (e.g. How to ride a bike). The second part was that of demonstration of that knowledge (e.g. Actually riding the bike). Here is the basic structure we used:
- We reviewed the basic structure of the system and felt the best way to roll this out would be to break this up by safety categories, such as PPE, Housekeeping, Hand & Power Tools, and Fall Protection. There were several reasons for doing this. First, the categories matched the observation checklists used. Second, each category was focused enough so that training could be done in a relatively brief time. Third, the knowledge was specific enough to the hazard, as opposed to a basic overview, such as from the OSHA training.
- Each category had both a knowledge and demonstration component identified. This involved developing training methodology that would be used to impart the knowledge, such as a training session. In addition, an activity was designed to demonstrate the knowledge, such as conducting a walkthrough with a safety professional or conducting a hands-on evaluation with tools and equipment.
- Training would include how to approach and coach as well to ensure observers positively interceded when they saw hazards and at-risk behavior and not just document them.
- Each employee would have a ‘qual card’ developed to show their progress, category by category.
- Each employee was limited to conduct observations based on their qualifications signed off on their ‘qual card’.
After rolling out this concept and implementing it, there were a few hurdles, such as finding the time for the individual attention to each employee. This was made more manageable by targeting those employees with the greatest need based on quality aspects, such as high frequency of 100% safe inspections, high frequency of PPE observations, and low participation overall.
The process was done in such a manner as to make it manageable (aka eating the elephant one bite at a time). The benefits turned out to be quite numerous such as defining clear expectations, confidence to participate and intercede, and increased communication.
Employee involvement is a vital part of any safety management system. For the involvement to be useful, it must be meaningful and mutually beneficial for the employee and the company. Structuring a program that defines the purpose, communicates it respectfully, and provides the tools necessary to fulfill the obligation is what is needed to achieve this benefit.
References
- United States Department of Labor, Occupational Safety & Health Administration (n.d.). Regulations (Standards - 29 CFR 1926.32(f)). Retrieved April 16, 2014, from https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10618
- Personnel Qualification Standard Program – NAVEDTRA 43241-K (2013). Retrieved from Naval Education and Training Command website: http://www.dcfpnavymil.org/Library/dcpubs/43241-K%203M.pdf