With limited resources, time and capacities, organizations must prioritize their actions and make choices about how they want to deploy people and tools to achieve continuous improvement. Respect for environmental, health and safety are part of any modern organization. While we can all agree with that statement, the real challenge arises when we try to “operationalize” our EHS programs.
Different countries and industries take different approaches to overcome this challenge. Some focus on management systems, some target compliance to standards and regulations and others train and leverage the staff. Of course, the vast majority of professionals will argue that we should do all three and that a good management system includes compliance and training. However, the most effective tool for creating a safe work environment and reducing risks is a focus on compliance.
However, the most effective tool for creating a safe work environment and reducing risks is a focus on compliance.
Culture can be difficult to pin down, whether it is safety culture or other types of culture. What exactly is culture anyways?
Culture can be defined as “the customs, arts, social institutions, and achievements of a particular nation, people, or other social group.” and Safety culture is “The product of individual and group values, attitudes, perceptions, competencies, and patterns of behaviour that determine the commitment to, and the style and proficiency of, an organization’s health and safety management” – U.K. Health and Safety Commission
The challenge with culture is that it remains a loose set of actions and values that bind a group together. Culture can change as people change. Most importantly, culture is very hard to measure. I am not trying to say that we should not aim for a safety culture at our organizations. Rather, I would argue that safety culture is the result of a series of actions and not the source of safety performance.
safety culture is the result of a series of actions and not the source of safety performance
Instead of starting with safety culture or even a management system, I strongly believe that we should build a robust comprehensive compliance program.
This includes the identification of an organization’s obligations, the actions it plans to take to meet those obligations and the means it employs to ensure the actions are attaining the objective of the obligations. Using a framework of compliance is a powerful tool to motivate and align people, teams and programs. Showing people the regulatory text or an industry standard allows you to demonstrate that it is not an “opinion” or something management cooked up, it is an agreed upon legally binding requirement that an organization must meet. By employing the raw materials of industrial management, you can begin to create a Compliance Culture. That is, you can begin to embed compliance into everyday workflow, build a foundation for your management systems and set expectations for individual behaviour in your organization.
Compliance driven programs have many advantages such as precision, clarity and quantification. In general regulations and standards are quite precise in their requirements and you can easily point to specific clauses or documents for reference. While some regulations are written in legalese, the general trend is towards more clarity from the regulators and additional documents to help contextualize the implementation of a regulation or standard. Lastly, and perhaps most importantly, you can measure compliance. If you know what you have to do and you know the actions it takes to do that, then you can easily audit and inspect and ensure your teams are staying compliant.
Next month we will be discussing the 10 EHS disasters in the last 20 years where non-compliance played a role. You can register here.