Making Companies Safe - what works? (CCA ... - Unite the Union

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A similar experiment in self-regulation, but one that applied only to firms with exemplary safety records within the construction industry, was California’s Cooperative Compliance Program (CPP). The program focused on seven large construction projects, each employing between 250 and 4500 workers. Participating companies agreed to establish joint labour-management safety committees that would carry out many of OSHA’s regulatory functions, whilst routine OHSA inspections were discontinued. 18 A rather different sort of initiative was the “Maine 200” program, which differs from VPP and CPP in that it was aimed at the 200 companies with the state’s highest levels of injuries. Participating companies worked cooperatively with OHSA to develop health and safety programs to identify and abate hazards and self-report identified hazards to OHSA. In return, firms were not prosecuted for any safety hazards or violations that came to light during the process, and were only subject to traditional inspection and citation in response to worker complaints, accidents and referrals. 19 It is important to note that even though OSHA introduced its first Voluntary Protection Programs (VPP) over twenty years ago, a report by the US General Accounting Office (GAO) published this year concluded that there had never been a systematic evaluation of either their individual or their relative effectiveness. 20 The evidence that does exist in relation to the impact of these programmes is contradictory. Participating firms and OSHA have claimed that VPP companies are achieving significant reductions in their injury rates. 21 And a report by the OECD refers to ‘evidence’ that firms participating in the Maine 200 Program in the United States achieved an overall reduction in compensation claims of 47.3% between 1991 and 1994 (as compared to a reduction of 27% amongst all Maine employers). 22 However, an analysis of the Maine 200 program commissioned by OSHA paints a more complicated picture. While OSHA reported that by 1995 employers had identified and reported hazards at a rate 14 times greater than would have occurred under traditional OSHA enforcement, Mendeloff makes three observations which cast doubt on the significance of these results. 23 First, half of the identified hazards came from four particular firms in the paper industry, all of which were unionised. Therefore the impressive level of hazard identification may not have been representative and may have been a consequence of strong trade union organisation and action on health and safety. Second, there was little information about the severity of the hazards identified in the companies’ self-surveys, so it was difficult to assess how they compared to the type of problems detected through traditional enforcement. And finally, whilst the companies claimed to have corrected around 68 per cent of the hazards identified, OSHA had no means of verifying this claim since all information on hazard identification and abatement came from the companies themselves. 24 In relation to assertions that companies participating in OSHA’s VPP, CCP and Maine 200 programs achieved impressive reductions in reported injury and illness rates, Needleman notes that: “the decline in workers compensation claims that accompanied the Maine 200 program can be explained in many different ways, some of them inconsistent with worker safety.” 25 In particular, there is evidence that reductions in workers compensation claims associated with VPP, CPP and Maine 200 may have been achieved through the internal suppression of reporting, and by placing workers on ‘light duties’, rather than through genuine reductions in lost time injuries and ill-health. 26 The AFL-CIO reports that many of the firms achieving VPP status have instituted internal systems whereby workers receive rewards or prizes when they do not report injuries and/or are threatened with and receive punishment if they do report injuries. An example of this is the “Accident Repeaters” program, which is based on the assumption that occupational injuries result from the unsafe acts of individual workers rather than from unsafe work environments. Any worker who reports two injuries in a period of two years will be placed on the Accident Repeaters program. The next injury they report is followed by counselling on how to be a safe worker or perhaps by compulsory attendance on a safety awareness-training program. Any injuries that are reported after this may be followed by a 85
warning, suspension and finally dismissal. 27 This belief that incidents are caused by the unsafe acts of workers, and the existence of punitive internal systems are also predominant features of specific safety management systems (see below). In addition, the AFL-CIO have found that some companies participating in the Maine 200 program achieved reductions in their injury rates by shutting down departments within the organisation that had the highest injury rates and contracting their work out to other companies. 28 In conclusion, while the HSE’s proposals for ‘earned autonomy’ are modelled on OSHA’s incentive-based programs and put forward on the basis of similar budgetary arguments, 29 no adequate systematic evaluation of these programs exists. 30 Moreover, the evidence that does exist is conflicting as regards the impacts of these programs on workers’ health and safety and suggests that there may be inherent problems in monitoring and evaluating outcomes. This is because narrow performance indicators, such as lost time injuries, are not necessarily accurate indicators of an organisation’s health and safety performance, and also because other outcome data – such as the number and severity of hazards identified and corrected – is reported by the individual organisation itself and may not be verifiable. Potential difficulties with the auditing and evaluation of ‘earned autonomy’, as well as more general questions concerning the regulation of such a scheme, will be discussed further below. However, first we will consider the more general empirical evidence that exists in relation to the impact of systems-based approaches to OHS management and whether these have the potential to create genuinely self-regulating organisations. Evidence Concerning the Impact of Systems-Based Approaches Since one of the conditions for achieving ‘earned autonomy’ status might be that organisations have adopted a safety management system that conforms to some specified standard, it is important to consider: • First, whether there is evidence that having a SMS does actually bring about improvements in OHS outcomes – namely reduced rates of injury, disease and death. • And second, whether there is evidence that introduction of a SMS stimulates a sufficient level of self-regulation and improvement to justify the withdrawal or diminishing of regulatory intervention. The Development of Safety Management Systems (SMSs) The development of specific OHS management systems (or SMSs) is based on the notion that the systematic and proactive management of OHS is more likely to bring about improvements to health and safety than reactive, ad hoc measures to address specific hazards: “Employers are being asked to move from policies that were often little more than ad hoc solutions to an array of known hazards to a more articulated set of structures and procedures for identifying, assessing, and controlling OHS risks.” 31 Saksvik and Quinlan note that the terms ‘systematic occupational health and safety management’ (SOHSM) and ‘occupational health and safety management systems’ (or SMSs) are often confused, but that formal OHS management systems are: “best viewed as a wide array of programmatic measures employers may adopt voluntarily or in an effort to meet SOHSM requirements.” 32 The development of formal SMSs is also a product of the development within management theory and practice of a systems approach to product quality and the related concepts of ‘quality assurance’ (QA) and ‘total quality management’ (TQM). 33 TQM, as defined by the European Foundation for Quality Management, is: 86 “The way the organisation is managed to achieve business excellence based upon fundamental principles, which will include: customer focus, involvement and empowerment of people and teams, business process management and prevention based systems, continuous improvement.” 34
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Making companies safe: What works?
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Acknowledgments: Courtney Davis wou
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Contents INTRODUCTION 7 MAIN FINDIN
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So for example, the new Strategy do
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“In recent years, there had been
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Chapter eight is a short chapter lo
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• The only sector-specific data o
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PART ONE Legal Regulation v Volunta
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self-regulation through the adoptio
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• A number of studies evaluating
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Gap in the law Yet despite the impo
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By September 2002 the Government ha
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Conclusion In conclusion, the Green
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effectiveness of safety representat
Page 32 and 33:
Chapter Four Conclusion There is ve
Page 34: PARTS TWO & THREE Strategies to sec
Page 37 and 38: A recent HSE discussion paper illus
Page 40 and 41: Chapter Five The Health and Safety
Page 42 and 43: Support for these findings comes fr
Page 44 and 45: Gray and Scholz attempt to understa
Page 46 and 47: perceived low level of current fine
Page 48 and 49: Chapter Six The Implications for th
Page 50 and 51: five times greater than if one had
Page 52: Select Committee on Work and Pensio
Page 56: The evidence reviewed in part two s
Page 59 and 60: health risk management between “a
Page 61 and 62: The relationship between knowledge
Page 63 and 64: Conclusion Whatever factors prompt
Page 65 and 66: 16 This was at an aggregate level.
Page 67 and 68: - the year that the initiative was
Page 69 and 70: When safety does not pay (or does n
Page 71 and 72: Similarly, firms might make an econ
Page 73 and 74: However, even in the context of mul
Page 75 and 76: does, exert a negative influence on
Page 77 and 78: to cost “a little” or “nothin
Page 79 and 80: For instance, when BP Grangemouth r
Page 82 and 83: Chapter Ten ‘Earned Autonomy’ T
Page 86 and 87: Whilst the original focus of TQM wa
Page 88 and 89: “the more firms incorporate ethic
Page 90 and 91: “In Norway the mandated model is
Page 92 and 93: odies, pressure groups and/or the m
Page 94 and 95: Health and Safety Management System
Page 96 and 97: Gunningham and Johnstone argue that
Page 98 and 99: Conclusion Proposals that some comp
Page 100 and 101: 37 The Norwegian Internal Control R
Page 102 and 103: PART FOUR Conclusion 103
Page 104 and 105: Chapter Eleven Conclusion The Healt
Page 106 and 107: Appendix Select Committee on Work a
Page 108 and 109: References Alder A., Tipping A. and
Page 110 and 111: Health and Well-Being’, in Frick
Page 112 and 113: Honey S., Hillage J. et al. (1997)
Page 114 and 115: Nichols T. and Armstrong P. (1973)
Page 116 and 117: Wokutch R.E. and VanSandt C.V. (200
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Making Companies Safe - what works? (CCA ... - Unite the Union

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