Managing Safety Performance: Compliance, Compliance, Compliance!

Paul Balmert

Paul Balmert is a graduate of Cornell University’s School of Industrial and Labor Relations, and his career in chemical manufacturing spans 30 years. In 2000, Mr. Balmert formed Balmert Consulting (www.balmert.com), a consulting practice that is principally focused on improving operations execution, including improving the management effectiveness in leading and managing safety performance. Mr. Balmert is the author of the best-selling book Alive and Well at the End of the Day; The Supervisor’s Guide to Managing Safety in Operations. He can be reached at pdbalmert@balmert.com.

May 1, 2017

When it comes to safety, every business leader wants exactly the same thing: for all team members to go home alive and well at the end of the day. The hard part is making that happen. In order to send everyone home safe every single day, every leader has to deal with a long list of tough safety challenges. The most difficult challenge is compliance, or getting everyone to follow all the rules, all the time. It is the most important safety challenge any leader faces.

If you don’t believe that, put it to the test. Thumb though a year’s worth of injury reports, and ask yourself, “How many of those injuries would have been prevented had everyone (or even just someone) followed the rules the way they were supposed to?” Every time I’ve asked, the answer is more than half—and this includes most of their serious injuries. It makes perfect sense: in the twenty-first century, there may be plenty of hazards, but there are also plenty of rules to keep people from getting hurt by those hazards.

This all makes a valuable point about managing safety performance: the shortest route to zero injuries is through complete compliance with all rules. There are challenges, of course, to actually having 100% compliance among all employees.

Compliance: What’s the Problem?

In theory, compliance is easy. No new polices or programs are required and all the safety rules are already written down. For the most part, everyone knows the rules—making the problem of compliance seem deceptively simple.

Of course, reaching full compliance isn’t as easy as putting out a memo reminding everyone to follow the rules all the time. If the compliance problem were that simple, leaders could move on to the next problem, which I like to call, “The Next Big Thing.” There always seems to be one of these new challenges competing for the attention of the leader. This points to part of the problem—compliance doesn’t require continuous improvement as much as it does continuous management.

The Rules

The compliance problem starts with the rules. Rules are carefully crafted, reviewed, and approved by those in charge, and this aspect of safety can be carefully managed by the company’s leader. Safety culture, on the other hand, is not written down and often does not reflect the wishes of management, and is a little more tenuous to get a grasp on. Developing a safety culture in which all employees follow all rules is part of the challenge for leaders.

Another part of the problem can be where exactly to find safety rules. Site safety rules can be seen during the site’s Visitor Orientation—but these are often sandwiched between what’s found in the corporate Safety Policies and Procedures Manual and the department safety rules.

Of course, if you are taking a Visitor Orientation, it’s likely because your company is doing work for a customer at their site. Let’s assume for the sake of this example that your company and your customer’s company rules are consistent and compatible. Then, you must consider the rules that come from the outside: federal and state agency rules, industry standards, codes, and best practices. One small example: electrical work. The paperback edition of the NFPA National Electric Code runs 910 pages. While not every rule applies to every electrician doing work in any operation, many of those rules do apply to those doing electrical work.

Clearly, there are a lot of rules to keep track of, and moreover, rules are in a constant state of change. Safety leaders have an immense challenge in both deciphering the rules that apply to any given situation and ensuring they are followed.

Knowing Versus Understanding

If someone doesn’t know the rules, they can’t be expected to follow the rules. Of course, people can both know rules and not follow them—this comes down to the issue of knowing versus understanding.

Critical safety activities where failure has a much higher probability of causing serious harm (e.g., entering a confined space, achieving a zero energy state, working at elevation, or around high voltage electrical systems) demand a high level of proficiency on the part of those assigned to do the work. Knowing the rules isn’t enough; understanding them is essential.

Ensuring employees fully understand all rules requires a 2-part process. First, you must confirm what employees know about the rules and hazards. Second, you must determine how well your training process imparts the necessary understanding.

Note the use of the term “training process.” Training isn’t just what the learner sees and hears when sitting in a training class or peering into a computer terminal; it also includes the demonstration of competency once the training has been completed. Oftentimes when put to a stress test, what’s labeled as training will be found wanting.

Remembering All Those Rules

It can be difficult for any one person to know how many safety rules apply in any given situation—in many cases only a tiny fraction of rules will apply to a particular person and project.

As to what rules apply, the answer in large part depends on the work being done. Insulators, scaffold builders, electricians, and engineers might all work for the same company on the same site and follow the same general safety rules, but they are exposed to different hazards and must follow different safety rules.

As to how many safety rules each person is expected to follow, the answer is a lot more than anyone thinks. Moving chronologically, tally up all the specific rules and requirements for any given project. Start in the parking lot, move to the job site, and then consider the assigned task of the day—the number of safety rules and requirements that apply to every individual easily runs into the hundreds. How many of those rules do you think anyone remembers?

Here’s where real-life operations work to the advantage of all; in practice, there is a relatively small number of safety rules that each employee uses on a regular basis. While that number is higher than most people think, it’s still a manageable number—and repetition and enforcement make it more memorable.

Repetition affords a huge benefit: it creates habit, making it easier to do something without needing to give it much thought. With repetition, remembering (and learning) becomes easy. Repetition, although it is a simple technique, is one of the most powerful weapons in a leader’s strategic arsenal to win the war on compliance. The bad news, of course, is that if what is learned isn’t put into practice, it will be quickly forgotten—this makes it absolutely critical to ensure that employees are following safety rules consistently at each project.

Situation Recognition

The rules for elevated work don’t apply when standing at ground level, a confined space permit isn’t required to enter the conference room in the front office, and the procedure to assure a zero energy state doesn’t apply when opening a door on a company pickup truck.

Those situations are so obvious, they seem silly. But, they demonstrate an important principle that governs the safety rules: most apply on an “if or when” basis. If something is going to be done, or when certain conditions exist, the procedure must be followed. The rest of the time, it need not.

In practical terms, that creates an additional variable in the compliance process: recognizing that situation or condition. Barriers can be put up (fences and tape) and signs can be posted (Vehicle Entry Permit Required or Authorized Personnel Only) making the situation obvious to the point where it becomes difficult to not recognize and comply with the rules. Other times, those doing the work are left to recognize and evaluate those conditions and situations as they arise. Processes such as pre-job planning and work permitting provide the check and balance of a second set of eyes—ideally an expert set of eyes.

Still, there’s an important role to be played by those who actually are in harm’s way. For example, a simple task can grow to include a more serious hazard (e.g., when working above ground level, but not too far off the ground). This is where the importance of judgement and safety training comes in.

Finally: The Matter of Choice

Even if someone knows and understands the rules, remembers the rules, and recognizes that the rules apply in their situation, there is no guarantee they will follow these rules. Those conditions are necessary—but not sufficient—to cause compliance. There’s still the matter of individual choice: choosing to follow the rules exactly the way they were written. Getting people to choose to make the right choice at the point of execution may be the toughest part of the problem with compliance.

One of the issues with compliance is that rules can often impede job operations by slowing things down, making a job more difficult, or even the basic issue of discomfort with personal protective equipment (PPE). The challenge of the safety leader is to impart the importance of following the rules, even when they seem like an imposition.

The Challenge of Compliance

Leaders face certain hurdles in ensuring compliance: making sure employees know all the rules, understand all the rules, and recognize and follow the rules as necessary. Managing compliance on the job site has to be a priority for any business leader. By offering proper training, imparting both the knowledge of and importance of following the rules, and ensuring employees practice these rules over and over, leaders can help ensure ongoing compliance management and safety.

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