How to Effectively Implement a Safety Management System

Hello, everyone, and welcome to the Case for Safety podcast. I’m your host, Scott Fowler. Appreciate you being with us today, where we’re going to be talking about common issues, common mistakes that organizations may run into when it comes to workplace safety and health. And here to share his insights on that, I’m very happy to welcome back to the show Greg Zagoulis, president of Sixth Sense Safety Solutions. Greg, welcome. Great to have you back on the show. Thank you. Glad to talk with you. Looking forward to the conversation now. As I mentioned, we’re talking about common issues organizations, EHS professionals can run into when they’re improving their safety management system.

So to kind of kick things off, I was curious throughout your career, what are some of those common issues, common mistakes you’ve seen in organizations as they’ve worked to improve their safety management systems? Well, I’ve seen a number of things, but as you are addressing those that are wanting to improve their safety management systems, I have to tell you that I still see a large amount of people who they really don’t even understand the need for safety management. They have this feeling that safety is all common sense. Nothing bad has happened yet. I don’t see why we should have to do a thing.

So there is that group of people or organizations who need to better understand the goal for occupational health and safety programs and what that is really all about. So for those that have that mindset or viewpoint, I recognize, of course, that we cannot identify all hazards in advance. We can’t perfectly predict things, but there are things, many things for which we could do huge good by having a system and programs and processes in place. So if you have that viewpoint, then the question can become, what exactly can be done? What should we focus on? What are we required to do? And what makes the most sense for us to do?

So of those who are attempting to work through, I would say one of the most common things I’ve seen is that the organization, they know they need to do something, perhaps, but they don’t necessarily clearly define their problem. They think that compliance with OSHA regulations or state plan regulations is the end goal. And in fact, many years ago now, I actually was speaking with an organization’s chief financial officer trying to make a case for a budgetary request. And this CFO basically, the first part of our discussion was him asking me, you know, why should we as an organization do anything more than comply with OSHA?

And it’s not necessarily that the person was evil or not well intended. It was that they came from a different background and just didn’t have an appreciation. or an understanding for the bigger picture of how safety systems can not only help prevent injuries but help the business overall. So that is one of the most frequently seen issues. Another is that many organizations that are trying to do better may have a checklist kind of approach to identifying their hazards. And maybe they pull up a checklist off the internet or some other book they have. And that can be a starting point. It can be helpful. But they don’t necessarily understand where those questions came from.

They don’t understand the underlying regulations. They don’t necessarily understand the concept of hazard identification. And so because of that, they may have these checklists. But then they don’t know what to do.

Well, first of all the checklist may or may not be on the mark Secondly when they identify issues They may have flawed processes for what to do with the information So they may feel overwhelmed if they identify a lot of things or they may get frustrated because they don’t understand the real meaning behind some of the questions so they could be overwhelmed, or they often will lack an ability to prioritize and estimate relative levels of risk to know how to make good use of the information. A third common issue I’ve seen is that organizations have taken an off-the-shelf, fill-in-the-blank template.

for a written program and they don’t necessarily understand the difference between individual topic specific OSHA programmatic requirements or written plan requirements as opposed to having a putting a system in place but really the bigger issue or the even more basic issue than that is that they take these fill-in-the-blank programs they may at one point in time fill in their company name in the insert company name airline, but not really take it and make it fit their organization, their culture.

Not that you might not want to work toward culture change, but I mean, there can be considerations for culture and how you go about implementing a program, nor does it necessarily fit their organizational structure, nor their processes. So what winds up happening is, the program sits on a shelf and it doesn’t get used. And in fact, I recall one fatality case that I had been asked to assist with where upon investigation of an organization where a fatality had occurred, what was found as part of that overall process was just exactly that. The company 20 years ago purchased something put it on a shelf and there it sat.

Their safety program became one of having a once a month safety meeting, which was more a matter of here, take the form sign and pass it along kind of thing. So it’s like you’re not trying to make use of the good information you could pull from in a written program and you’re not making it make sense. And then I guess another issue I’ve seen is drift over time. So maybe an organization starts off with what could be considered a reasonable or even a well-written safety program or plan or maybe it was intended to be a system at one point in time. But maybe they don’t have the in-house resources. Maybe they used a third party to come in and help create something over time.

they adapt to what they do based upon successes. They make changes, people come and go, and they wind up performing in the field or the plant or in their services, things that are different from what they originally intended, but they don’t really realize it because they don’t have a comprehensive approach or a more complete approach. And then the last thing that struck me with that question is that especially for newer organizations that are not as mature, I guess you could say, in program development and implementation is there is a lot of information out there in the marketplace about health and safety programs.

There are lots of different concepts floating around about what the company should do, what they shouldn’t do. Sometimes the ideas are conflicting. So I see that companies really can fail to think critically through what they themselves, based upon their industry and their business, should do for themselves. Thinking about those different circumstances you just laid out, it could be a number of things that could lead to organizations struggling with this.

But when you think about boiling it down to the circumstances that can lead to these kind of things, is it really you know, organizations either, you know, they don’t know what they’re dealing with or, you know, they get some handle on what they’re dealing with, but then they don’t know what to do from there. That’s a great question. And I think of it this way, in our country, when someone’s starting up a business, you know, there is this, this myth, this aura, this, you know, I’m going to start up a business and make a success and so on.

And those kinds of processes when you start things up, you tend to start small, unless you have a really great idea and some venture capital behind you to create something huge. But you’re probably going to start off as a smaller organization. And let’s say I start off with just myself or just a few employees, and let’s say I’m not a safety consultant, but making some other good or providing some other kind of service, I’m probably not going to start off I don’t have the money in the business, the market circumstances are not such that I’m going to start off tacking on a full time dedicated health and safety professional. That’s just not in the cards at that point in time.

But hopefully it becomes hopefully those people in that kind of circumstance would call upon someone for some assistance as as might be needed. But so there’s the business startup consideration and just the reality of starting up an organization in some cases or, you know, in other cases, if it’s an established business, they’re a smaller business and you have someone, some organizational leadership could be wearing five different hats at the same time. So it becomes a matter of asking, well, do we know what we need to know? What do we need to do? How do we Figure out what we really have to do and then What are some economical ways for us to work through that thing?

But you don’t start off in a smaller organization usually with someone who Health and safety and environmental programs or their passion not usually the other thing is that It can be very difficult for certain business models and in certain industries and you know the way certain companies get their work, whether it’s business to business or what have you, it can be difficult for them to pay for safety up front and to have safety integrated in what they do up front. It might be something they can work on hopefully over time and later.

I mean, obviously, there’s no provision in OSHA that says that just because you’re a small organization starting off, that if you’re doing certain kinds of work that you don’t have to comply with the OSHA regulations. I’m not saying that by any means, just that you can get better and more sophisticated over time depending on the circumstances. But it’s also a matter of people who, based on the way business often works, they don’t see an incentive to include safety up front. And I think in part it’s a lack of understanding on their part of how safety can potentially really, again, be not only something good for the people, but for the business as well.

But Scott, I’m reminded of a company that I had worked for once upon a time. I’ll leave it like that. They were expanding certain processes and they needed to have, they really needed to have certain occupational health. processes in place that involved air sampling and respiratory protection programs and occupational medical monitoring. And the viewpoint of the people that I was working with at the time, the project managers, who didn’t, they just didn’t know better, the viewpoint I received from them initially was, why should we do all that?

We don’t know upfront that we need this or that, which actually, you know, if you looked at the regulatory requirements based upon what they were working with, they very clearly were going to need to have certain things in place. But the other part of the attitude, unfortunately, was, you know what, when people come work in this situation for us for a while, it can take, how long does it take for certain long related diseases to develop? Oh, well, you know what? By the time the disease develops, they’re not going to be on our payroll. And to them, they thought, hey, that’s doing business.

Or the other organizations that those workers may go work for in the future, that would be their problem, as opposed to working proactively up front. And again, I think that ties to… a lack of understanding of some basic health and safety principles in the bigger picture. It gets right back to that viewpoint I mentioned earlier of compliance. Why should I do anything but comply? And that’s where part of our role, well, our role as health and safety professionals should be to help organizations better understand those issues and to coach in the right direction.

So your initial question about what sort of leads organizations to these sorts of circumstances, I would say are that it’s partly systemic issues, but it’s also partly the human element. It’s partly the need to be sure that we are including the people working in those systems and to help influence that culture. Another frequent thing I’ve seen has been unfortunately misaligned incentives, which is kind of where people who don’t know better often are incentivized in certain areas that can be contrary to worker health and safety.

And so, you know, that lack of understanding, we can partially help address through if we have a health and safety management system in place and in good communication in place. What you just touched on there, you know, you’ve got different, you know, different organizations of different sizes that are at different maturity levels when it comes to safety. But think about it in broad strokes, talking about, you know, these gaps that exist within organizations, you know, how can organizations help close those gaps? Whatever size the organization might be, how can they help close those gaps? And to your point there, how can EHS professionals help them do that?

I think initially, especially for a small medium-sized enterprise or micro business that they may need some form of external resources initially. I think how you address those gaps changes over time, depending upon business growth and market area and what have you. But I think organizations really can best work through those things by having some form of a roadmap that they can follow in a relatively disciplined way.

So instead of being reactive and just responding to sudden expectations that maybe you didn’t know about or hazards that you didn’t know about, to in fact be more proactive, have a proactive governance type model, proactive means of identifying hazards and having a process for working through what you identify. So if you have a roadmap that can be followed over time, the other thing that an organization should keep in mind is that making change in an organization isn’t just about knowing the technical aspects of what to do. It’s also the human element, the organizational change aspects. So you’re going to want to manage that process for improvement, for health and safety.

or environmental issues, just like an organization would want to go through it for other types of business issues. So you can’t just tell people, be safe today. I really care for you. Now go out and don’t get hurt, okay? You have to help them understand. You have to provide tools. You have to provide some framework. Right. And to your point, like you’re a small business owner just getting started, maybe you don’t have the funds to bring on a full-time safety person, but to ask yourself, okay, what can I do to help protect my workforce, you know, give them the education, the training they need to stay safe when they’re doing their job?

I think persons in that role need to really get a lay of the land and to understand where some of the drivers may come from that would either mandate by law that they have to have certain programs in place. or that just makes sense for them from a business risk reduction standpoint. So it can be a matter of looking at these different factors, conducting some research on your own, potentially reaching out to maybe you have peers within the organization that already are there or a corporate parent that can help. Sometimes there are other resources you can look towards.

Each state basically has a program of some sort in place that’s intended to help small organizations understand their issues, right? Many people are hesitant to reach out, not understanding that usually those people you reach out to really are a distinct arm. They’re separate from the regulators. So understanding… some of the things that you might need to work through or what you might be obligated to put into place, you then need to work towards really understanding what the hazards are within your business and your organization. So it’s not one size fits all.

So an organization can look towards, oh, maybe historical data, they can look at trade or industry related publications, they can read PSJ. But there are lots of places people can go to to find common sources of injury. Of course, OSHA has their website, which is really a very good website, where people can look based upon their industry codes to look for common citations, as well as common types of injury.

And then to work with that, hopefully have a process then to see how that data and information really can apply to your organization and to conduct assessments that you may need to do for your organization, whether you do it yourself or with the people you have, or maybe when you’re just starting off, you bring in some third party of some sort and over time that may change, but you need to start with something right. Talking about resources, you mentioned like professional safety journal and Ocean is one, I know you’re heavily involved in our NCA SSB standards.

Folks out there might be even familiar with Z10 or a standard like ISO 45001, particularly for those who may have, as we mentioned, limited means to be able to go out and get a copy of the standard. How can implementing a standard like that help organizations get on the right track, regardless of their size? Well, really what I found over time is that there are different issues in different size companies and within different industries. So I think that the answer can vary depending upon the context. I would say actually for larger organizations, there can often be a in-house staff with a good level of sophistication. They may have a lot of things in place.

but they maybe want to compare what they’re doing to what other experts consider to be beneficial, helpful, supportive of a sustainable safety and health program and system. And so they could look to something like the ANSI ASSP Z10 standard for occupational health and safety management systems.

And I think that actually the Z10 standard has a lot of good framework to it and some supporting documents so that if someone wanted to look at Z10, you can look at not only the basic description of what these experts from across the country and across several different industries believe to represent important elements of a safety management system, but there are other supporting documents that give a lot more context and explanation. that can be super helpful. And in fact, one of the documents that is part of the Z10 family is really about health and safety programs in small and medium sized enterprises. And as I understand it, that document is available for free download through ASSP.

It’s high demand and it’s got lots of people who felt it to be very helpful to provide a framework for moving an organization from wherever they’re at, one state of maturity, one state of development, and moving them along. Now, some will argue that, hey, we’re a large organization, why do we need to put this management system in place or that management system in place? So there are those who would argue that, but my answer to that would be, it’s an excellent framework to help people stay attuned with having this great framework. but smaller organizations as well.

And especially smaller organizations that, you know, maybe they don’t have a good feel for what they should include in their health, I’ll call it health and safety program, you know, whether you want to call it program or system. And there is a difference between a program and a system. But let’s say you’re a smaller organization, you know, you need to do something, you’re trying to do the right thing, but you don’t know what to do. And in fact, I saw that. firsthand in my experience over time, Scott, with companies is I would work with different organizations, different sizes, different parts of the organization.

And the feedback I would get is, you know, we want to help our organization be safe. We want to be compliant. We want to do more than be just OSHA compliant. But you know what, I really, I don’t know what else I can do. What are some of the other things we should be doing? Well, if you look at Z10, That gives you a very good framework for what a total approach could look like. And of course, organizations can take that and make it fit to them. Exactly. And we will make sure to include links to Z10 and those other documents you mentioned with this episode so folks can take a look. Any final thoughts? Anything else you’d like to add? Well, I would say that…

An occupational health and safety management system, if you take a system approach, it can become something more of the organization than just a safety tool. It can be something that can really be a business optimization tool, right? So there can be both the financial, direct, injury prevention aspects of implementing a Z10 standard, but there are all these other benefits that organizations can achieve.

And I think it can also, you know, if you are a health and safety professional and you are working in an organization where leadership may have questions about why they need to do things or they may not always feel that certain things need to be done that should be done, operating with an OHSMS framework can help provide a communication process. It can help make language more understandable and consistent between groups. It can help with business integration. And I think it can really give folks an approach that ultimately can help them when they have to make those cases for making changes and improvement, it helps them articulate why. Very well said.

Thank you so much again for coming on, Greg. I know we’ve got a lot of listeners out there. I’m sure have run into these issues over time and they want to do the right thing and just need to find a way to get on the right track. So I really appreciate you coming on and sharing how they can do that. So thank you so much again. You’re very welcome. Thank you. We hope you’ve enjoyed this episode of the Case for Safety podcast. Be sure to subscribe on Spotify or Apple podcasts. and be sure to leave a review to help others find the show. You can also connect with us at ASSP.org. We’ll see you next time.