I have many clients who believe that completing Formal Hazard Assessments are a waste of time and add nothing meaningful to their health and safety management systems. They believe that site-specific hazard assessments are of much more value in protecting workers from harm. I offer the following thoughts regarding Formal Hazard Assessments and their usefulness.

Reasons for Completing a Formal Hazard Assessment

• Help management to meet regulatory (Occupational Health and Safety) and Industry (Certificate of Recognition) standards.
• Distinguish work site hazards and control measures based on established processes.
• Save money and resources by being proactive rather than reactive regarding health and safety issues.
• Reduce incident frequency and severity in the workplace.
• Classify risk management standards based on acceptable industry and legislative requirements.
• Engage employees and create a sense of well-being and awareness among the workforce.

Terminology

The use of interchangeable terminology, regarding hazard control methods is where, I think, most people-safety professionals included, get into trouble.  Hazard assessment is not difficult subject matter, but it is confusing.  In this article, I will be using the terminologies established by the Alberta Partnerships in Injury Reduction, Certificate of Recognition Program.

Types of Hazard Assessments

There are several ways that safety practitioners identify, assess and control hazards, the most common being: Formal Hazard Assessments, Site-Specific Hazard Assessments (PJHA, FLHA, etc.), Hazard IDs, and Management of Change/Deviation.

In this article, I am only going to discuss Formal Hazard Assessments.  Formal Hazard Assessments should be the first step used by organizations to identify, assess and mitigate hazards faced by employees. These appraisals should be completed for every job/position, whenever a new position/job is added to the organization, when there are significant changes to work scope/operation/equipment, etc., and when an investigation or inspection has identified deficiencies in work processes. All too often, I have witnessed Formal Hazard Assessments being completed as a last step in the process, only required by Certifying Partners to satisfy Partnerships in Injury Reduction (PIR) standards, and as such, many managers and safety professionals deem them at best, of little use, and at worst, unnecessary and unworthy of their time and effort.

Steps to Completing a Formal Hazard Assessment

• Identify all jobs/positions within the organization i.e., President, Administrator, Welder, Truck Driver, etc.
• Determine all tasks completed for each position, i.e., powered mobile equipment operation, computer work, welding, stock shelves, working with power tools, etc.
• Pinpoint health (bacteria, air quality, pesticides, stress, etc.) and safety (working at heights, working with powered equipment, sharp edges, rotating equipment, etc.) hazards for each task.
• Classify all hazards using a risk assessment system of your choosing. The most common and accepted standard is severity, frequency and probability.
• Once all hazards have been prioritized, i.e. evaluated according to risk, distinguish and implement control measures based on the hierarchy of controls (engineering, administrative, and PPE), legislative standards for your jurisdiction, industry requirements, and manufacturer obligations.

When Completed The Following Should Have Been Learned:

• Which jobs/positions present the most threat to employees.
• Which tasks pose the most risk to employees.
• Wherein specific tasks lie the most risk.
• What types of inspections and frequency standards are required.
• Are employees adequately trained to competently complete their job assignments.
• Are supervisors appropriately trained to oversee operational processes.
• Are adequate engineering, administrative and personal protective equipment controls in place.
• Have suitable and compliant equipment and building preventative maintenance programs been established.
• Has the risk to workers been lowered to acceptable levels.

What Do We Do Now?

• Develop job/position specific training standards for all employee groups based on proven facts.
• Establish a company and job specific on-the-job training program to enable new or untrained workers to learn from senior personnel.
• Install a training regimen for middle managers and supervisors to ensure they can get the best performance out of subordinate workers.
• Determine how often site-specific hazard assessments and inspections should be completed based on validated truths.
• Distinguish and develop Safe Work Procedures (SWPs) based on identified high risk factors. Once completed, SWPs can be added to the formalized on-the-job training program.
• Budgets can be established so the management team knows in advance the resources required to run the safety program, i.e., training, purchasing, maintenance, man hour cost, etc.

Conclusion

I hope this article has helped you to realize the benefits of completing a Formal Hazard Assessment. Formal Hazard Assessments are arguably the best way to determine, assess and control hazards faced by workers. Most importantly, used in conjunction with other hazard assessment processes, Formal Hazard Assessments can and will effectively engage workers, promote positive behaviour, increase health and safety awareness, strengthen efficiency, while consequently reducing the number of and severity of incidents. Therefore, this will reduce costs associated with incidents, boost profitability and viability of the organization, and can also be used as a promotion tool aimed at attracting more customers.

Have you been thinking about incorporating management software to your computer to control your health and safety program?  Questions abound: Is it too expensive?  Is it too difficult for employees to run?  Will it be too cumbersome to implement?  These are some of the queries I am regularly asked.

Electronic health and safety management systems (SafetySync, EHSInsight, KellerOnline, etc.) are certainly not new but have been slow to gain a foothold in the business world.  Even when used, their power is seldom fully utilized.  This article has been written by a computer-challenged health and safety professional, not a computer geek or programmer, who has become a strong proponent of these platforms.

What will an electronic program do that my current, paper based, system will not?

An electronic system will:

1. Most importantly, save the organization money.  Expenditures are reduced because administrative duties (completing, reviewing, filing forms) are shared by all employees.  These duties are also done more quickly, accurately and seamlessly with computer based programs.
2. Increase “boots on the ground” time.  Studies show that approximately 50% of a safety person’s job is spent on administrative duties.  Keyboarding for 20 hours per week means less time on the shop floor, in the field, etc.  A health and safety practitioner’s productivity is greatly hindered by being “chained to a desk” at the office.
3. Modernize and streamline the process of developing and maintaining directive documents, tracking employee qualifications, accumulating and filing reports, disseminating reports, and understandably, presenting them to non-safety professionals, e.g., managers and supervisors.
4. Increase the time spent on identifying improvement opportunities and assigning corrective actions since information is captured, analyzed and transferred to statistical graphs and charts in real time.
5. Raise health and safety awareness and accountability for senior and middle managers, supervisors and workers through timely reports and statistics.  Consequently, employees will become engaged in health and safety activities, which will build morale and compliance.
6. Identify key performance indicators (KPIs), which enables the organization to become proactive rather than reactive in their decision making.  Moreover, this helps to reduce risk, improve and measure performance, and provide evidence on where to make considered, fact-based decisions.
7. Grow legislative and industry conformance by tracking and applying worker training as required.
8. Reduce the effort required of front line supervisors and workers because information is captured, transferred and filed electronically.  There is no need to write a report (inspection, hazard assessment, hazard ID, observation tour, etc.), send it to a manager/supervisor to review, and then forward it to the administrator for filing.

Negative aspects of implementing health and safety management software

1. Some management platforms cost tens of thousands of dollars to develop and implement, which is out of touch with what most companies are willing to spend.  Increased competitiveness in the delivery of these programs has greatly reduced fees to as little as $5.00 per month per employee.
2. Employees are older and/or not technologically savvy; this is just an excuse.  All employees, young or old, can be taught the basic skills needed to run these types of programs.  Besides, computer skills are an essential component of most job positions; hence, additional training should be considered an asset rather than a liability.
3. While it is true that setting up an electronic health and safety program can take a considerable amount of time, which translates into added cost, most platforms, however, have on-line or in-person training regimens so that you can set up your own program, or you can hire a professional to do it for you.  The benefits of having an electronic program, as listed above, far outweigh the time spent to set them up.

Conclusion:

I encourage companies, large and small, new or established, to embrace changing technology as they do in other aspects of their business.  You would not think to have your accountant work with a calculator and hand written spreadsheets, and you should not handcuff your health and safety professional(s) in the same manner.

The main updates are in the area of senior manager and supervisor knowledge of their responsibilities and their health and safety programs.  The new practices will also include an emphasis on site-specific hazard assessments.

Most CPs are trying to make their new audit standards available for voluntary use well before the deadline in 2019.  This is in an effort to reduce the shock on companies needing to establish or improve their directive or report documents prior to being scrutinized during renewal audits.  The hope is that companies will use the new benchmarks in their maintenance audit years, to define variances in their programs, compared to the updated tool.

2019 Partnerships Audit Protocol Availability

The Alberta Association for Safety Partnerships (www.aasp.ca) is adopting, in its entirety, the PIR’s standard.  This new audit tool is supposed to be available for use in mid to late summer 2017.

According to the Alberta Municipal Health and Safety Association (www.amhsa.net) website, their new audit rule should be approved by Partnerships and be available for use in early 2017.  At the time of writing, this tool was not available for use.

During a presentation to the Alberta Occupational Safety Auditors Association (www.aosaa.ca), Juliet Goodwin, Manager of Safety Audit and Certification at Enform (www.enform.ca), explained that their new audit instrument would not be available for use until shortly before the deadline of January 1, 2019.

Change is Good

It is encouraging to see the government is requiring the CPs to better their audit procedures on a regular basis moving forward.  Times and trends rapidly change, and so should health and safety management evaluation systems.  Although this can be challenging for front-line health and safety practitioners, it is necessary to promote continuous improvement and to protect the health and safety of workers.

Variance Evaluations

As the new audit protocols become available we, at Constant Safety Inc., will be making gap analysis templates available for companies to gauge their compliance.  Drop us a line, we will be happy to forward a copy to you.  Currently, the AASP/Partnerships audit tool is available for download from our site (http://constantsafety.com).

Why are so many construction workers being injured, maimed or killed while working at heights?  Construction activities are inherently dangerous and made more so when employers do not heed industry and legislative standards.

The majority of non-compliance issues take place at residential work sites.  Industrial and commercial workers are much more likely to be working for companies with established safety programs in place in order to be able to bid on work.

Take a look around any residential construction project and I guarantee that you will find non-compliance issues.  Infractions include: no guardrails/barriers, no approved anchor points, not wearing harnesses, harnesses do not fit properly, lanyards not affixed to approved anchor points, lanyards that will not arrest the fall until worker strikes something below or beside them, etc.

Statistics

A review of government compiled health and safety statistics for 2016 show that in Alberta (http://work.alberta.ca/occupational-health-safety/statistics-and-employer-records.html), 34% of all work-related fatalities occurred in the Construction and Construction Trade Services.  Twenty-three companies were charged with OH&S violations and six of those (26%) were for contraventions of fall protection standards (falling while installing a window, falling from a roof while clearing snow, falling from a roof while re-seaming panels, etc.).  Meanwhile, in British Columbia (https://www.worksafebc.com/en) in 2015, thirty serious construction fall incidents were reported.  Of those, 67% included fatalities and fractures (ankles, arms, legs, vertebrae, etc.).

Legislation

Current legislative standards obligate employers to assess work sites and job tasks to identify, measure and mitigate hazards.  These requirements also state that employers must follow the hierarchy of controls when determining constraints.  The hierarchy includes elimination, substitution, engineering, administrative and personal protective equipment.  Elimination or substitution are the best options and should be considered, but are not practical in most of the instances we are discussing.  That leaves engineering, administrative and personal protective equipment (PPE) controls:

• Engineering controls for people working at heights include: railings, barriers, safety nets, travel restraint systems, etc.;
• Administrative controls include: pre-job hazard assessments, fall protection plans, fall protection procedures, employee training, signage, etc.;
• PPE controls include but are not limited to fall arrest systems (temporary anchors, connectors, full body harnesses, lanyards, and shock absorbers).

Legislation also states that if PPE is required, management will ensure that workers receive training in their use, care, maintenance and limitations.  Management also has a duty to guarantee the availability of the equipment and the utilization thereof.

Why the Non-Compliance

Industry publications and interviewed workers cite numerous reasons that fall systems are not being used.

Ill-Fitting/Uncomfortable Equipment. At one time, this may have been a legitimate excuse, but it is no longer acceptable.  There is a plethora of equipment providers and styles of equipment to suit every need.  Each worker should be given the latitude to find the right harness for his or her body type and work style.  One size does not fit all.  If we want workers to wear protection, the equipment has to be comfortable and usable.

PPE Limits Ability to Work. As stated above, fall protection equipment must provide ease of movement for the wearer.  If it does, there is no loss of productivity.  Productivity can increase because workers can be confident they are adequately protected.

Workers Feel Less Safe When Using Controls.  Wearing something for the first time takes some getting used to.  The more a worker uses the equipment, the better they feel about it.  This is about building a culture of health and safety.  Once established, this will be no different than wearing a hard hat or safety glasses.

PPE Reduces Productivity.  Management must take a leadership role to make certain that workers wear PPE and use fall protection systems.  In a very competitive marketplace, this can be difficult to achieve.  The elimination of “piece work” can be an effective starting point.  Giving workers the time to complete fall protection plans, conduct pre-job hazard assessments, and inspect equipment for defects can go a long way to ensuring compliance.  Senior managers should remember that production is negatively impacted whenever an inspection or investigation is required.  Serious injuries and fatalities reduce efficiency; preventing them increases productivity, reduces costs and provides a sense of well-being among workers.

Solutions

Formal hazard assessments (task based) should be completed to determine the risks associated with the work performed.  Control measures should be adopted based on the hierarchy of controls, legislative standards, industry requirements and manufacturer suggestions.  All companies should establish fall protection policies and procedures for their particular work environments. Training requirements and regimens should be established.  PPE ought to be purchased to suit particular worker types and preferences.

Once all of these are created, ensure supervisors and front line managers hold workers accountable for applying and abiding by the control measures set forth.

Ignore the Facts at Your Peril

Health and safety officers, when investigating workplace incidents, focus their attention on management team members, as it is they who oversee and guide the activities of workers; very, very seldom do workers injure themselves on purpose.  Also, managers hold the purse strings of the organization.  Current laws allow for administrative penalties that can reach into the millions of dollars, as well as possible incarceration for egregious offences.

With the availability of high quality engineering products, training materials and personal protective equipment, there is no excuse for suppliers and prime contractors not to have obedient safety programs that are assured to protect rank and file workers.

My last post (Health and Safety Auditor Ethics) outlined some of the current unethical standards being practiced by a surprisingly large number of health and safety auditors in Western Canada. Moreover, these individuals are tarnishing the Certificate of Recognition (COR) program and the reputations of the majority of good-intentioned and law-abiding evaluators.

COR Compliance Statistics 2016

At the recent Alberta Occupational Safety Auditors Association workshop, a presentation by Jessica Meyer from the Alberta Partnerships in Injury Reduction (PIR) program indicated that non-compliance regarding auditing standards has increased dramatically year over year. She pointed out the data was not finalized, but current statistics showed that 62% of the completed On-Site Audit Review (OSAR) evaluations for 2016 required some form of follow-up action. This is an increase of 7% over 2015 numbers.

These figures are troubling for several reasons: 1) They show an upward trend in violations since the OSAR program began; 2) They show a lack of compliance and understanding by health and safety professionals; 3) It shows that the COR program is being undermined by unscrupulous auditors in almost two-thirds of the audits reviewed; and 4) It shows a serious lack of professionalism and respect for employers and workers alike.

Certifying Partner Response

Currently, Certifying Partners have two ways to hold auditors accountable for completing their duties in a compliant manner. Firstly, they conduct meticulous Quality Assurance Reviews on all audits submitted by internal and external auditors. This process includes: ensuring audit time frames are adhered to, interview and work site samplings meet Partnerships standards, no boiler plating compared to other submitted audits, etc.

The second course of action includes government involvement and intervention. When a Certifying Partner suspects a violation, they can ask the government, through the Partnerships program, to conduct an OSAR audit.

If found to be in contravention, auditors face disciplinary actions, such as verbal and written reprimands, suspensions, and/or outright dismissal.

Government Involvement

Due to the fact that many COR approved companies were and are paying hefty Workers Compensation Board (WCB) surcharges, the Alberta government devised a program to evaluate a finite number of annual external and renewal audits.

The system entails a government assessment to determine if there is an appropriate synergy level between formal standards and the audit being evaluated. If serious irregularities are found, the government instructs the Certifying Partner to rectify them with the auditor involved.

Although an OSAR is a comprehensive assessment, it is seriously underfunded by the current Alberta government. OSARs are capped at 100/year, which means that approximately 4% of external and renewal audits are gauged. Besides that, Alberta and to a small degree, British Columbia, are the only provinces applying this standard.

Additionally, there is no mechanism other than quality assurance reviews to determine if internal/maintenance auditors are adhering to applicable rules and codes of conduct. Internal/maintenance audits account for the majority of COR audits conducted annually in Alberta (approximately 7,500). There is no reason to believe that reviews of those audits would differ from those of external auditors.

Path Forward

It is clear, given the statistical information, that the auditor accountability process being used by governing bodies is not working as needed or intended.

I would suggest that 10% of all audits (external, renewal or maintenance) be subjected to an OSAR. If adopted, this would be a ten-fold increase to 1000/year. Furthermore, I would also like to see increased penalties faced by abhorrent auditors.

Substantially increased government funding, coupled with escalated administrative penalties, would put deviant auditors on notice that their behavior will no longer be tolerated. Moreover, it would increase the profile of the COR program, reduce WCB costs (both employer and government), and most importantly, aid employers in maintaining a safe, healthy and productive workplace.

Ultimately, it is the health and safety of front-line workers that is put at risk by these abhorrent practices and increasing their exposure levels is just not acceptable.

Due to the economic uncertainty in Western Canada and beyond, and the fact that safety is the “flavour of the day”, I and my clients are seeing a marked increase in unsavory business practices and behaviours from external and internal health and safety auditors.  All Certifying Partners require auditors, once accredited, to sign a Code of Ethics standard which outlines duties and responsibilities.  Auditor training courses, for most Certifying Partners, last from 3-5 days and include in-depth reviews of policies and procedures.  Therefore, unscrupulous individuals cannot hide behind the “I didn’t know” excuse.

Common codes of conduct infractions include: not conducting enough interviews to meet prescribed standards, not asking all pertinent questions to interviewees (employee interviews require at least 30 minutes to complete), not conducting enough worksite observation tours, not conducting thorough worksite observation tours to prove out documentation and interview findings, and boiler plating of audits.

All of these unprincipled behaviors are used to circumvent the process and to steal work from legitimate auditors.  Currently, many companies are in dire financial situations and are scrambling just to keep solvent.  In order to reduce cost, these employers are using the cheapest options available to them to attain and maintain their Certificate of Recognition designations.  In some instances, organizations are fully aware these auditors are not fulfilling their obligations, but the temptation to reduce expenses is so great they often turn a blind eye.

It is up to the government in charge of your jurisdiction, your Certifying Partner, external auditors, and you, as representatives of your company, to make sure you choose a properly accredited and ethical auditor to conduct your Certificate of Recognition audits.  The consequences of not meeting proper standards can be quite severe and range from loss of COR status, regulatory penalties, and in some extreme cases, can lead to serious accidents and even fatalities.

It is my sincerest wish that auditors who participate in underhanded practices be disciplined to the fullest extent possible. These individuals are tarnishing the image of the majority of law-abiding and hardworking health and safety auditors.  I encourage fellow auditors, business managers and owners to report any and all deviant behaviour to their Certifying Partner.