Perspectives on Safety Programs from the Safety Roundtable

Gary Auman

Gary Auman (www.amfdayton.com) is a Partner in the law firm of Auman, Mahan, and Furry in Dayton, Ohio. He graduated with an electrical engineering degree from the University of Louisville in 1969 and a law degree from The Ohio State University in 1976. He served in the U.S. Air Force from 1969–1973. His practice focuses on counseling and defending employers in safety and health matters. In 2002, Auman was awarded the Distinguished Service to Safety Award by the National Safety Council. He is a staunch advocate for safety in the workplace and is an aggressive advocate for employers who have been cited by OSHA, defending employers across the United States. He has worked with OSHA in its development of safety and health standards and frequently works with employers and OSHA to find workable solutions to OSHA enforcement actions. Auman also represents 4 national and regional trade associations in the construction industry. He can be reached at gwa@amfdayton.com.

October 1, 2008

What kind of a safety program does your company have?

There are many possible answers to this question, including the following:

  • “I don’t know.”
  • “We don’t really have a safety program, because we have never had a bad injury.”
  • “With the economy the way it is right now, we can’t afford to do too much on safety.”
  • “We’re too small to have a safety professional.”
  • “Our Human Resources person takes care of that issue.”

Those who are having trouble answering this question should consider attending the Safety Roundtable session at the National Insulation Association (NIA) Annual Convention. In the years that this program has been presented, it has been one of the best attended and most interactive sessions at the convention. Yes, safety has become a hot topic. Safety is important. Safety is not something that can be ignored.

The Safety Roundtable at the NIA Annual Convention brings together many companies, including the winners and top finishers for the NIA Theodore H. Brodie Distinguished Safety Award. These companies share their experiences with regard to safety and pass on their ideas and information about their safety programs.

This article will discuss some of the concepts and ideas shared at this year’s Safety Roundtable by both the Safety Award winners and by their peers who attended the session. These comments apply to all employers, including insulators, manufacturers, and end users.

Safety Enforcement—and Reinforcement

One complaint that many companies often make concerns their inability to get employees to comply with safety rules and use their safety equipment. The heart of this problem is the fact that most companies do not have an effective safety enforcement program. This particular issue was probably the one most discussed at this year’s Safety Roundtable.

One insulation contractor—not one of the largest in the industry—shared his very effective safety program. He said he has learned that an effective safety program requires effective enforcement and that he is determined that his employees must take safety seriously. He is concerned with not only the effect on the bottom line, but also the impact a serious accident can have on the morale of all employees, especially with a small contractor.

To make his safety enforcement program effective, he has taken it to the next level. All warnings—even verbal warnings—provided to employees for safety violations are documented in the employee’s file. He also shared that with every safety violation and every disciplinary action, the employees at fault are retrained. This is a key aspect of having an effective safety program. Just telling them they have done something wrong is not necessarily the most effective way to correct their behavior. Perhaps they did not understand how to properly wear the personal protective equipment (PPE), why they should engage in certain safe conduct, or why a particular safety rule applies to the job they were performing. Rather than guess at whether retraining is needed, this contractor makes sure each employee who receives discipline for a safety violation is retrained. That retraining explains to the employee where and why he or she went wrong and how to avoid making the same mistake again.

One additional aspect of this company’s safety enforcement program was quite interesting: When an employee receives a safety disciplinary action, a copy of the disciplinary action is provided to the employee’s spouse. This action by the employer demonstrates to the spouse that the employer is concerned with the health and well-being of the employee. If the employee is injured, it also provides the spouse confirmation that the employer was doing everything possible to protect the employee from injury. Probably the most effective aspect of this program is that a spouse who receives notice of a disciplinary action is going to do everything possible to ensure that the employee begins complying with safety requirements and starts doing things correctly. Keeping things happy at home is a tremendous motivational force for the employee to comply with safety rules at work.

Another contractor shared an experience with a more strict enforcement program for management than for line employees. In some areas, the Occupational Safety and Health Administration (OSHA), as part of settlement agreements, is requiring employers to establish more stringent safety rules and a higher level of disciplinary action for management employees than for non-management personnel. One example provided was as simple as having a four-step disciplinary program for non-management employees, while management employees are subjected to a three-step disciplinary program. Therefore, a supervisor who violated a safety rule had three strikes before they were out, whereas a non-management or non-supervisory employee would have four strikes.

Another concept was that supervisory employees would be disciplined not only for their own safety rule violations, but also for violations by their employees. Of course, they would have available the defense of unpreventable employee misconduct in such a situation, but they would have to meet the same level of proof that the employer would be expected to meet when defending a safety violation in front of OSHA. This provides a tremendous incentive for management employees to not only comply with safety themselves and set a good example, but also to ensure that employees who work for them are complying with the safety rules.

Safety Incentive Programs

From discipline, the discussion moved into the area of safety incentives. Safety incentive programs might seem straightforward and relatively similar among different companies. However, as those in attendance learned, there are almost as many safety incentive programs as there are companies to administer them. Various attendees at the Safety Roundtable contributed information about their safety incentive programs. Their ideas for safety incentives included providing cash rewards to employees, having raffles where employees can win trips, and allowing employees to purchase items from a product catalog after accruing points through the safety incentive program and safety compliance.

All attendees agreed that safety incentive programs need to be tied to safety compliance, not lost-time injuries. Tying an incentive program into not having injuries at all or not having lost-time injuries is counterproductive. This encourages employees, especially through peer pressure, to “work hurt,” which can cause an increase in subsequent disability and seriousness of the injury so they can obtain a safety award.

Different ideas and criticisms were provided during the roundtable on incentives. Some attendees said cash rewards are not a good idea because once the money is spent, there is nothing for employees to see or hold on to that reminds them of the safety incentive. Others felt that using premiums for which an employee accumulates safety incentive points was a better idea, as long as the items would last for quite a while to remind employees of their safety performance.

Attendees raised concerns about safety incentive programs that rely on the lottery system. This system only rewards a few people at a time, and some employees might never benefit from a safe work performance because of the “luck of the draw.” Unless the system is structured so that all employees who work safely are guaranteed to receive some reward for that performance, a lottery system is not advisable. If the employer decides to have a raffle system that eliminates previous winners for the remainder of the year or until each employee has been rewarded, employees who are no longer in the system may lose that additional motivation to work safely.

No one should require an incentive to work safely. Unfortunately, some employees have become set in the way they perform their tasks without safety equipment or without concerns for safety, and it is difficult to motivate them to change their bad habits. Frequently, an incentive program is necessary. The bottom line is that the cost of an on-the-job injury is so significant that the cost of an incentive program pales in comparison. If a company is going to have an economic incentive program, management should consider one in which all employees who meet the criteria for an incentive receive one.

Are Employees Trained for That?

The final topic that was discussed by those in attendance at the roundtable was one concerning training and orientation. One company suggested that while most employers provide all safety equipment and PPE for their employees, some companies suggest that employees bring some of their own personal equipment. This may be equipment necessary to perform their job or certain types of safety equipment. This particular employer found it helpful to give new employees a list of equipment they should bring on the first day of work. This way, the employee has all the gear necessary to begin working safely on the first day. This list includes all the safety equipment provided to the employee by the employer on the first day of work.

Safety training and orientation take the following two basic forms:

  • Safety training provided to employees on the day they report to work
  • Ongoing communication to keep employees tuned in to safety issues throughout their entire working careers

Those in attendance shared their concepts of initial orientation of new hires. This ranged from providing new employees information on the company’s drug and alcohol policy to providing the 10-hour OSHA course and going over the company safety manual and safety compliance rules. Several attendees suggested new employee safety mentoring programs, where an experienced journeyman is assigned to each new employee to bring them along from the safety perspective. One or two companies suggested providing new hires either decals for hard hats or different colored hard hats for their first 60 to 90 days. This lets experienced employees keep an eye on new hires from a safety perspective, as well as from a productivity and quality of work perspective.

Most attendees agreed that even experienced employees need continued safety training. This can be accomplished by weekly toolbox safety meetings, daily safety job briefings, and periodic quarterly or semiannual company-wide safety meetings. In addition, if a company has not provided the OSHA 10-hour course to employees when they first are hired, most in attendance agreed that it should be provided during their first year or so with the company.

The information provided at the Safety Roundtable is varied and very helpful. Managers who have never taken the opportunity to participate in one of these valuable meetings should think about doing so at the next NIA Convention in April 2009.