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By Daniel S. Cote
Senior Vice President, MEMIC
All too often, it is assumed that poor workplace conditions are the direct cause of workplace injuries. That is the basic premise by which the Occupational Safety & Health Administration (OSHA) conducts its business. Although poor workplace conditions are certainly a factor in the Safety & Health equation, this article proposes three other factors in the equation that exert a greater degree of influence—at MEMIC, we call it the culture-based safety process.
The culture-based safety process incorporates a simple philosophy toward safety. We believe that every organization has four basic business elements that integrate well with safety. As the business works to attain the most effective safety process, each business element must be strengthened and improved equally and simultaneously, and not at the expense of one over the others. These four business elements are:
•Culture
•Human Resources
•Medical Management
•Workplace Conditions (not to be confused with “OSHA Compliance”)
These four building blocks, described below, contain many components. Our assessment tools, training programs, and business consultation practices are designed with these components in mind. Accordingly, the principles and language set forth in the culture-based safety process are embodied in all documentation and correspondence generated by the safety consultants on our team.
The culture-based safety process, combined with industry best practices, offers the customer a holistic approach to safety. When I speak of industry best practices, I specifically mean those industries for which MEMIC provides coverage, such as transportation, manufacturing, health care, retail, and so forth. Thus, it is important to remember that the four business elements discussed below are a foundation that supports a particular industry’s best practices for operational excellence.
1. Culture
The component requiring the greatest amount of time, leadership skill, and attention to people is the company’s safety culture. Culture change, or improvement, means that the management team is truly engaged in ongoing benchmarking and measurement of leading indicators to produce a climate conducive to safety. This is also the component that offers our insureds the greatest opportunity for reduction in injuries.
2. Human Resources
Hiring the right person to do the job is fundamental, but often overlooked in the rush to get someone to do the work. This component is one both of great opportunity and, if poorly accomplished, of tremendous volatility. Developing and following an appropriate hiring process is essential to a successful safety process. Just as important is the appropriate training and education of front-line supervisors in the areas of communication, understanding performance fundamentals, motivation, constructive feedback, discipline, and documentation.
3. Medical Management
Essential for the cost management of injuries and alleviating the human toll, this component is often misunderstood by managers and viewed, inappropriately, as the driving force of a safety program. It requires a formal plan, careful attention to detail, communication, and a dedicated person to manage the process. Although a medical management program is a major cost saver, it cannot supersede accident prevention.
4. Workplace Conditions
Assessing workplace hazards and making physical working conditions better are fundamental; they are the most basic form of safety improvement. OSHA standards and industry best practices often dictate the direction and amount of work to be done in this component. Often, the easiest of the four business elements for managers to understand as requiring emphasis and improvement, all too often, it inappropriately becomes the one and only, de facto route to measuring safety performance.
The following chart illustrates the concepts discussed.
The Details: What’s Needed to Achieve Culture?
 Culture
1. Industry-Specific Leading Indicators for Safety
•Industry-specific, safety-related leading indicators (such as waste, overtime, turnover, inspection results, etc.) are identified and integrated into the safety and health effort.
2. Cultural Safety Assessments
•Culture-based assessments are conducted internally, perception surveys are made, and safety behavior is measured.
3. Organizational Safety Goals
•The organization has a safety mission statement signed by its President/CEO.
•Senior management identifies measurable company safety goals that integrate with the business goals, specific safety activities are formally assigned to each level of management, and accountability is achieved through goal measurement and rewards.
4. Employee Involvement in the Safety and Health Effort
•Employees participate in departmental/companywide safety-related projects and meetings.
•Safety is a topic that is integrated into the business process.
 Human Resources
1. Formal Hiring Process
•A formal, written hiring program is in place that includes written applications, employee interviews, reference and background checks.
•The new employee orientation addresses industry-specific and regulatory safety requirements.
2. Progressive Discipline Policy
•A written policy exists, enforcement and documentation are consistent.
3. Job Descriptions
•Job descriptions, functional capacity exams, and where appropriate, drug and alcohol screening.
4. Performance Evaluations
•Objective safety goals are included in performance evaluations.
•Incentives are contingent upon achievement of safety goals.
5. Injury Trending by Department
•The organization prepares internal trending reports.
•A financial charge-back system holds departments accountable for claims.
6. Dedicated Human Resources Personnel
•Human resources personnel are on staff with collateral duties.
7. Drug and Alcohol Policy
•Preplacement drug testing is provided for all employees, and post-accident and/or random drug testing is given to employees involved in safety-sensitive operations.
8. Leadership/Management Development Training
9. Employee Benefits
•Medical insurance program is in place.
•Long-term and short-term disability programs are provided.
•An Employee Assistance Program (EAP) is provided.
 Medical Management
1. Formal Medical Management Programs
•The organization has a written medical management process that identifies responsibilities, includes a purpose statement, an injury-reporting process, and a claims-reporting process. The program affirms an established relationship with a medical provider(s) and the availability of transitional, return to work on a case-by-case basis.
•The transitional, return-to-work program is in writing, asserting a functional capacity analyses.
•Nonwork-related health conditions (either temporary or permanent) are taken into consideration when assigning transitional work.
•The organization has access to an occupational health professional who proactively conducts work hardening.
 Workplace Conditions
1. Formal Safety and Health Standards and Policies
•OSHA regulatory requirements for the industry are complied with, and the required training is provided.
•Best practices/industry standards are proactively established.
2. Hazard Assessment Tools and Processes
•Safety assessments are routinely conducted.
•A joint management/employee committee reviews safety assessment data and analyses trends in safety performance.
•Job hazard analyses are conducted for all job classifications.
•Executive management reviews safety performance data.
3. Ergonomic Assessments
•Ergonomic training is provided at three levels:
1) Stretching programs;
2) Work/job task training; and
3) Supervisor leadership in ergonomics
•Accident investigations include an emphasis on ergonomics, and injury trends are documented.
•Job hazard analyses are conducted that result in recommended corrective actions, and ergonomic principles are integrated throughout the company.
4. Formal Accident Investigation Program
•A joint management/employee committee investigates and documents all accidents and incidents, identifies the root causes (which indicate the engineering or behavioral issues that are involved) and implements solutions.
•Supervisors are actively involved in the accident investigation process, and executive management reviews all reports of accidents.
5. Equipment Maintenance Standards and Practices
•A comprehensive preventive maintenance program exists for all machinery and equipment.
6. Dedicated Safety and Health Personnel
•Full-time safety and health professionals are on staff.
7. Subcontractor Safety Program
•The organization obtains a certificate of insurance from subcontractors before they start the project.
•The organization conducts pre-assignment safety meetings with subcontractors.
•A formal program exists that includes subcontractor orientation and training as well as work-site inspections by the contracting organization.
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