When developing and implementing an OSH system, stakeholders must consider a vast array of factors for the system to be effective. Having a nonoptimal system not only hinders the ability to identify and address risks and hazards, the system itself can present risks to the business.

While there are a number of common, well-known missteps that organizations make with their OSH systems, there are other, less frequently discussed mistakes that nonetheless can have a major impact on system efficiency and effectiveness, including:

1. Having an unbalanced program.

Many elements go into an effective OSH system, but if there is not a proper balance between those elements, then the system as a whole will not operate at maximum efficiency. OSH professionals should bear that in mind that every component of a safety system plays a part in its success, and no one element should be emphasized over another.

It would be a mistake to downplay one component because it is viewed as not as important as another. For instance, a company should give the same attention to technical and engineering elements as it does to cultural elements, and occupational safety should not be viewed as more critical than occupational health.

It is important to view an OSH system as being greater than the sum of its parts. If all or most of the attention is given to one particular element of the system, then the other components will suffer, leading to the increased potential for illnesses, injuries and fatalities.

2. Assuming that low incident rates are directly correlated to low fatality rates.

Organizations may think that there is a direct correlation between occupational injury rates and fatality rates. However, by taking a closer look, it becomes apparent that such a correlation is not the case. On the contrary, some larger organizations have OSHA-recordable injury rates well below the U.S. average, while their occupational fatality rates are above the national average.

According to the Bureau of Labor Statistics, in 2014 the oil and gas industry had the lowest total recordable incident rate per 100 full-time employees per year (TRIR) of the four industries selected (oil and gas, construction, manufacturing, and education and health), and the highest fatality rate per 100,000 employees per year. On the other hand, the U.S. education and health industry had the lowest fatality rate and the highest TRIR of the selected industries.

These statistics demonstrate that organizations should not equate low OSHA recordable incident rates with a decreased risk of serious injuries and fatalities (SIFs), and that a closer examination of organizational data is necessary to develop a truly effective OSH system.

3. Having impractical safety expectations.

While every organization would like to have zero injuries and fatalities, that is not realistic given the many factors involved. In certain environments, it simply is not possible to achieve absolute control over all risks and hazards.

Rather than try to mitigate or eliminate any and all hazards, organizations should instead determine an acceptable level of risk and take steps to achieve it. It is important for organizations to establish from the outset realistic expectations for their OSH system, as well as acceptable risk in order to optimize safety performance.

Methods such as the as low as reasonably practicable (ALARP) principle developed by the U.K’s Health and Safety Executive (HSE) provide organizations with guidance on determining their level of tolerable risk so that they can prioritize and mitigate risks and hazards to an acceptable level.

4. Confusion between occupational safety and system safety. 

As noted, there must be a balance between the different elements of a management system for it to be effective, and that includes a balance between personal safety and process safety. Many organizations put a greater focus on personal safety issues, since those are easier to measure. However, personal safety metrics are not necessarily an accurate representation of overall system safety and effectiveness.

While measures such as lost workdays can provide an indication of overall personal safety, they do not take into account factors such as engineering and management issues that affect system safety. Furthermore, the precursors of personal safety incidents vary greatly from those of process safety incidents, and organizations should develop measureable criteria for both in order to prevent incidents and optimize their OSH systems.

5. Confusion between intentional violation and error.

A common misconception in the OSH field is that when safety violations occur, they are conscious, willful acts on the part of an employee. However, in reality this is usually not the case. A significant number of incidents can be attributed to human error rather than intentional safety violations.

By taking this into account when developing or improving their OSH systems, leaders can work with safety professionals to implement well-developed safety controls that will mitigate or eliminate the impacts of human errors.

6. Assuming that no errors will be made if employees support safety. 

One critical element to a safety program’s success is the commitment of everyone in the organization, from the top-down. However, organizations cannot assume that no errors will be made if everyone supports safety.

While it is nice to believe that everyone will act in the safest manner possible at all times, errors do happen and that should be figured into an OSH system. If the system is designed so that it can anticipate and react accordingly to errors before they become incidents, it can have a major impact on overall safety performance.

7. Lack of clarity on duty of safety care at multiemployer sites.

Multiemployer sites with potentially dozens of workers performing different tasks and facing different hazards can create confusion as to everyone’s roles and responsibilities in terms of safety.

Having a clearly defined duty of safety care can help provide clarity about who is responsible for safety at the site and how risks will be mitigated. The duty of safety care can depend on statutory, contractual or controlling-action obligations for a particular employer, and having one in place is an important element in developing control measures for multiemployer sites.

8. Nonoptimal safety organization design. 

For an OSH system to achieve its purpose, it must be properly selected, designed and implemented to meet an organization’s specific needs and business objectives. Having an isolated OSH department or adopting a one-size-fits-all approach would most likely not move safety performance or the business in the right direction.

Organizations should develop a structure where occupational safety is integrated into every aspect of the business. With such a structure, every employee from the C-suite down will know their roles and responsibilities in terms of safety in order to optimize safety and business performance. 

9. Failure to prioritize risks. 

While organizations would like to address all the risks and hazards associated with their operations, the reality is that resources are limited and management must make choices as to which hazards to address based on the level of risk they present to employees.

Failing to prioritize risks can result in resources being stretched thin and greater attention being given to less frequent and less severe injuries, rather than examining less obvious hazards that may have more serious consequences. Leadership should have clearly defined priorities, strategies and tactics for addressing risks that will effectively and efficiently achieve the goal of protecting people, property and the environment.

All of these circumstances emphasize the importance of conducting periodic OSH system audits and risk reviews to comprehensively gauge the system’s effectiveness. Without taking a hard look at the system, leadership may assume, incorrectly, that it must be working because the organization hasn’t had any significant injuries or fatalities. It is crucial, however, to not equate a lack of injuries with an effective safety management system and take steps to continuously assess the impact that the system is having on overall safety performance.

To read the full version of “Business Risks: What Happens When Leaders Are Committed to Nonoptimal OSH Systems?” which originally appeared in the February 2018 issue of Professional Safety, click here. Want to receive a monthly subscription to Professional Safety, ASSE’s top-ranked member benefit? Become an ASSP member.

Related Links

Managing Risk Perceptions: Safety Program Support Outcomes

The Art of Assessing Risk

Multiemployer Sites in the U.S.: Project Control & Duty of Safety Care