Building an Effective Safety Culture

Building an Effective Safety Culture
More tools for the Safety Professionals Toolbox
Presented by:
● Jim Rhoad
● Dustin Boss
Certified Risk Architects with Ottawa Kent Insurance

Welcome: Building an Effective
Safety Culture
● Welcome to our discussion on
Safety Culture and going Beyond
the Safety Program
● We are excited to be here and
looking forward to discussing safety
culture and the best ways to
develop one at your place of
business.

Management Buy-in Essentials
● A lot of elements are important
when implementing a safety
program and even further with a
safety culture.
● But none of them are going to
matter unless top management
buys in and allows a safety culture
to develop

Elements in Safety Culture
● Element #1 - Management,
Leadership and Employee
Involvement.
● Element #2, – Prevention
Worksite Analysis and Hazard
Prevention and Control.
● Element #3 – Pro-Active Safety
and Health Training and
Education.

Management doesn’t know, what they don’t know
● Few top business leaders
can tell you how to develop
and enhance their safety
culture.
● And more importantly why
they should even want a
safety culture in the first
place.

Obtain Management Buy-In
● As the safety manager, HR
person, owner responsible for
safety results and building a
safety culture your first and most
important goal is to get buy-in
from your management team.
“Effective safety management systems are woven
into the fabric of an organization,
becoming part of the culture, the way that people do
their jobs.
—National Safety Council website (2013)

Goals
● The goal is to have top
management (everyone) believing
that a good safety culture can and
will help to reduce injuries and
illnesses along with the associated
hidden costs. Also, a good safety
culture can...
● increase efficiency
● improve productivity
● morale
● and/or quality of products
● and reduce the potential
for regulatory citations
“Today managers are changing worker behavior by coaching employees
and teaching safety leadership skills, so that employees can make safe
choices on their own. The culture of safety establishes expected patterns
of behavior.
Managers don’t just threaten employees. Instead, bosses and co-
workers are empowered to reward one another when something is done
the right way. And you, the safety manager, are the one who makes it
possible.” -360training.com

How do we get there?
● What are businesses in business
for? To be safe? No! It's about the
money!
● And don't confuse money for
greed! Business owners may
report to a board, they need to
meet revenue goals, etc.
● Management teams must agree
that safety does save money!
● Before we get into developing a
safety culture business owners
should understand the implication
of cost to your business. ……
EDUCATE MANAGEMENT: Quick
Review on potential costs/liabilities
businesses face:
• Work Comp Claims
• Experience Modification
• Return to Work
• Contesting Citations/ Lawsuits

Financial Impact Of Claims
Hidden costs can have a sizeable impact on a business’s profitability. A
business with a 4-percent profit margin must sell an additional $125,000
in products or services to pay for just $5000 in hidden accident costs.

Break it down...To cover a $5,000
claim...
● A soft drink bottler would have to
bottle and sell more than 61,000 cans
of soda
● A food packer would have to can and
sell more than 235,000 cans of corn
● A bakery would have to bake and sell
more than 235,000 donuts
● A contractor would have to pour and
finish 3,000 square feet of concrete
● A ready-mix company would have to
deliver 20 truckloads of concrete
● A paving contractor would have to lay
900 feet of two-lane asphalt road

FREE TIP-OSHA’S Safety Pays
● https://www.osha.gov/dcsp/smallbusiness/safetypays/estimator.html
Employers can use the “Safety Pays" to assess the impact of occupational injuries and
illnesses on their profitability. This program uses a company's profit margin, the average
costs of an injury or illness, and an indirect cost multiplier to project the amount of sales a
company would need to generate to cover those costs.

● As you can see, incidents are
more expensive than many
business leaders realize!
● Beyond that, there are many
hidden costs that are not truly
understood.
● Some costs are obvious while
other costs are transparent.
● Your workers’ compensation
claims cover medical costs and
indemnity payments for an injured
employee. These are the direct
costs of incidents.
Direct Vs. Indirect Costs

Much more than just medical and wages!
● What about the costs to train and compensate a
replacement employee?
● Repair damaged property or equipment,
● downtime of equipment
● investigating the incident,
● implementing corrective actions?
● OSHA Fines
● Even less apparent are the costs related to
● product schedule delays (production delays)
● added administrative time,
● Business reputation
● lower morale,
● increased absenteeism,
● pain and suffering of the employee,
● and impaired customer relations.
● These are the indirect costs and, as such, have been
described by many professionals as an iceberg. You
cannot see the bottom until it is too late

Costs are rising
● In the real world, management can be
perceived as risk-takers, willing to do
anything to be competitive with other
companies to produce a profit.
● However, on the other side of the
spectrum, there is one gamble that
can be a sure loss for any manager
● Gambling on employee safety and
the risk of incidents that can cause
injury or property damage [11].
● Managers are now coming to realize
that the actual cost of a lost
workday injury is underestimated.

Experience Modification: Split Point Change Impact
● Due to inflationary trends in loss severity, the split point should change over time to remain sensitive to
disparities in loss experience. However, NCCI hasn’t increased the split point since 1991, despite a
significant increase in the average cost of claims. Beginning Jan. 1, 2013, NCCI will introduce changes to
rectify this by increasing the split point in non-monopolistic states (click here for effective dates PDF).
● Why is it changing?
Ultimately, the effectiveness of an experience rating modification system lies in its ability to accurately and
consistently differentiate between, and adequately correct for, disparities between policyholders.
$-
$5,000.00
$10,000.00
$15,000.00
$20,000.00
$25,000.00
OLD 2013 2014 2015
Primary
Excess
*Example of a $25,000 claim under the current split point and what it will look like under the new changes

Experience Modification Impact
Under the old formula, any ratable individual loss up to $5,000 was known as primary loss (those given full weight and reflect
frequency) and excess losses (those given partial weight and reflect severity) was anything greater than $5,000. In other words,
the portion of an employee injury considered primary and accounting for 100% in the experience mod calculation is set at $5,000. All
claims over the split point are discounted by the weighting factor. For individual claims below $5,000, the entire amount is primary loss
and excess loss is $0.
Due to inflation, policyholder modified premiums, especially for those policyholders with exceptionally good or poor loss experience, are
no longer adequately modified. As a result, “good” risks are overcharged and “poor” risks are undercharged. This reduces the incentive
for policyholders to maintain or improve their workplace safety standards and practices.
How is the split point changing?
For NCCI states and most independent bureaus (including Michigan and Wisconsin) the experience modification split point will be
changing according to the following schedule:
Date Split Point
2013 $10,000
2014 $13,500
2015 $15,000 + 2 years Inflation to closest $500
Beyond 2015 Inflation matched to 2015 level
NCCI is estimating that 78% of mods will be impacted by +/- 5 points when the $10,000 split point is applied. With this change, the
minimum experience mod that any business can achieve will decrease due to the increase in expected primary losses.
What does this mean? In the short term if you have a claim over $15,000 it will cost you more. Essentially with
payrolls the same a debit mod could get worse and credit mod could get better.
In the long term every business will have greater control over costs by taking control of their
losses. Workers’ compensation is the only line of insurance where employers have the ability to control costs. This is
done by hiring the right people, creating safe work environments and implementing safety policies, selecting the right
physicians for injured workers, developing effective return-to-work programs, etc.

TIP-Work Comp Surcharge
WHAT TO KNOW:
 Current Experience Modification Rate
● Check accuracy
 Minimum Experience Modification Rate
 Claims Analysis
● Indemnity vs. Medical Only
*Experience Modification is biggest
indicator for work comp pricing

Return to Work Program
Information from the Bureau of Labor Statistics states that:
● Only 50% of employees who are off work for six months with a work-related injury will
return to work
● Only 25% of employees who are off work for one year with a work-related injury will return
to work
● Employees who are off work for two years with a work-related injury have virtually no
chance of returning to work
WHAT DOES THIS MEAN?????
GET PEOPLE BACK TO WORK AS SOON AS POSSIBLE

Return to Work- Template
STEP 1-Establish Written Return to Work Policy
Create a written document signed and agreed on by
management. This is the basis to implementing an
effective Return to Work Program and all changes must
be communicated with your employees.
STEP 2- Assign Responsibility
1- Senior leadership needs to be the force which
changes the culture
2- HR (Safety/Health Professional)
Depending on the size of the company you will most
likely assign this to HR unless you have the luxury of a
full time health professional.
3- Work Comp Coordinator- Acts as the liaison for all
work related and non-work related injuries and illnesses.
This role will oversee the work comp program, Return to
Work Program, ADA, FMLA
4- Manager/ Supervisor- Accountable and responsible
for the safety management practices implemented in his
area.

STEP 3- Job Safety Analysis
Establish a written job description for each job
category within your organization. Define the major
tasks performed and list all related knowledge and
skills required. Each specific job task should be
identified as either essential or non-essential to the
job.
STEP 4- Hiring Practices
Place the right person in the right position to reduce
work compensation risks/claims. Take the time to
have a thorough interview/ on-boarding process.
establish orientation and training programs for new
and transferred employees.
STEP 5- Medical Provider
Work with and select a qualified medical provider

STEP 6- Incident Investigation
What happens after an incident occurs?
STEP 7- Manage the Claim
Effective claims management is more than just
waiting on the insurance company and injured
employee. With the correct claim management you
can make the process hassle free and reduce the
pain of increased costs and surcharges.
STEP 8- Return the Employee to Work
Depending on the strategy and severity of the claim
the employee will eventually be back to work. Make
sure that if they are able not to return to their full time
job, the transitional job is within the injured
employee’s restrictions.
*This is a brief outline of creating a Return to Work
Program and by no means has all the information you
need. Within each step there are many more
elements that are crucial for the program’s success.

Why RTW matters
Example of EMOD rate equations:
If the three-year history of experience rating for an operation was 1.10, 1.00, 0.88, the
payment history would be:
1.10 × $38,233 = $42,056
1.00 × $38,233 = $38,233
0.88 × $38,233 = $33,645
What About My Profits?
The direct and indirect costs related to an accident or incident can have a dramatic effect on your
profitability. The following example identifies what these costs can mean to you. (In this example
we’ll arbitrarily use $8,500 as the average direct cost of a single cumulative trauma disorder.)
Direct Cost = $8,500
Indirect Cost = $34,000
Total Loss $42,500 (this case is four times the direct cost — some cases may be as high as 10 times the
direct cost)

● Shifting liability back to
employee.
● The premise is that is would be
unfair to cite the employer who
has promoted safety, trained his
employees for something that
could not be prevented.
(essentially what an accident is)
Contesting Citations:
Un Preventable Employee Misconduct

Contesting Citation:
The OSHA Field Operations Manual says to
prevail on the affirmative defense of
“Unpreventable Employee Misconduct –the
employer must show that it…
1. Established a work rule adequate to prevent
the violation (Safety Policy)
2. Effectively communicated the rule to
employees; (Training, safety committees,
signed agendas or quizzes)
3. Established methods for discovering
violations of work rules, and yet did not
know about an isolated violation of the work
rules; and (Audits dates and findings)
4. Established effective enforcement of the
rule when violations are discovered
(discipline policy in handbook and
document discipline even verbal)

1- Create a written Safety Policy
● Must address the hazards most
frequently encountered by your
employees.
● Work rules must be as strict or
stricter than the OSHA standards.
● Work rules need to be in writing.
● Work rules should be distributed to
all
● Have employees sign and agree (Handbook
and Safety Policy)
● General Standards in Safety Policy

2) Communicate the rules to your employees
● Ensure new employees are
properly trained prior to being
sent to work.
● Examine your orientation program: New Hire and Worker Transfer
● No “grace period” granted by OSHA for new employees.
● Signed Forms for safety policy and handbook
● Continued training-Risk
Management
● Videos, personal reviews or work
● Educate employee regarding most frequently encountered hazards
● Industry specific risks
● Review portions of work rules and OSHA standards
● Distribute hand-outs

2) Communicate the rules to your employees
● Maintain documentation
● date, names of individuals in attendance,
trainer, translator, detail specific topics
covered, job site or location of class
● Hold class in Spanish as well as English
● Safety Committees
● Management should run or be involved
● maintain strict records of meeting agendas,
sign in sheet and subject matters
● Discipline supervisor for failure to hold
meeting or for failure to return
documentation in timely manner
● Periodically use guest speaker or do
demonstration to enforce safety
● Insurance Agent, Risk Manager
● Other Vendor- Fleet Safety, Hi-Los,
Wellness Coaches, OSHA Consultants

3) Take Steps to Discover Violations
● Safety inspections, walkthroughs, audits
● Detect hazard
● written up hazards condition and abatement taken
● Detect work rule violation
● write up employee(s)
● Use other resources to do periodic safety
inspections
● Company safety representative
● Top company management officials
● Worker compensation carrier
● General liability carrier
● Outside consultant/auditor
● Sub-contractor
● Question laborers

4) Discipline: Enforce and document violations
● Does your company have a disciplinary system?
● Is it in writing?
● Is it in or referenced in the work rules?
● Do the employees know they can be disciplined for violation of
work rules?
● Do the supervisors know they can, and will be disciplined for
failing to discipline an employee for violating the work rules?
● Do you document verbal warnings?
● Do you track discipline?
● Have you suspended or terminated an employee for violating
your safety rules?
● Are employees aware that other employees have been
disciplined for violating work rules?
● Your safety program must enforce the safety rules
● Document discipline

Prove the Un Preventable Employee Misconduct
QUESTION: OSHA cited my company because an
employee was found not wearing safety glasses. There
is no dispute the employee was not wearing the glasses,
or that it was required (it is), but the employee was
violating our strict safety glass policy. Do we have any
defenses?
To have evidence to prove the Un Preventable Employee Misconduct
defense you need to demonstrate that:
1. Employer has an established PPE policy that addresses the
type of PPE for which the employer was cited;
2. All employees (including the employee who was found not
wearing the PPE) have been trained on the PPE policy;
3. Employer conducts regular audits of the workplace to ensure
employees are following the PPE policy
4. Employees are disciplined when they are found to be in violation
of the PPE policy (or other safety rules).

Educate management to get Buy-In
● Now that you have some tangible numbers to
influence your ownership you can get buy-in.
1. Experience Mod Info
2. Claims Cost
3. Work Comp Surcharge from mismanaged
claims
4. Potential for contesting violations and
lawsuits
● Once you have the buy-in, then business leaders
say, go for it!
● Build a safety program
● “BUT I expect to have no injuries! Make it
happen! SAVE ME MONEY….Or else!

Here is the “quick fix” to create safety
program
● To build your safety program, you’ll
have written safety programs or
plans. Which kind you create will
depend on your industry, but
common programs include:
● Fall protection
● Hearing, respiratory, and/or
vision protection
● General accident prevention
● Personal protective equipment
● Hazardous material handling
Common components of
workplace safety plans include:
• Risk assessment and consultation
• Safeguarding (machines or
processes)
• Employee competency training
• Document retention
• Change management
• Technology solutions
• Safety committees
• Return-to-work procedures
following incidents
• Incident investigation and reporting
• Inspections
* Note we do encourage and recommend every company to implement written safety plans and components into their workplace.
However this is like a band aid to an amputee. It is not a long term solution

Building a safety program
● Safety programs typically consisted
of the usual things: for example
● safety meetings
● facility inspections
● incident investigations to some
degree (not getting at the root
cause) (identify solutions), with
little emphasis on identifying
and correcting hazards.
● Most professionals perceived these
tools as the essential elements of a
safety program.

Does management really buy in?
● But then they walk into the plant
floor without safety glasses
● Forced overtime
● Skipped safety training because
production was in need
● Lower budget for PPE
● But we, as safety managers, are
still responsible for no injuries!!!
● NO CHANGE IN CULTURE
WITHOUT MANAGEMENT BUY IN

Safety Culture- Go Beyond the Safety
Program
● That brings to the core of
our seminar today.
● How do we move beyond
safety program and get a
safety culture?

No Silver Bullet
● Let me let u in on a little secret...
● There is no silver bullet
● And...unfortunately, it may not be
possible for you!
● A safety culture requires an certain
view of management and
management style.

No Silver Bullet
● What works in one organization may
not in another. Each organization
must determine for itself what will
work for it.
● There are several major concepts.
● The answer seems to be clear: it is
the culture of management and the
employees of the organization that
determines what will work in any
organization

What is your culture?
● Certain cultures do have safety as
one of their major constituent values,
and not a priority.
● Other cultures make it very clear that
safety is unimportant. In the latter,
almost nothing will work;
● Meetings will be boring
● Hide claims
● No disciplinary action
● job hazard analysis (JHAs) are
perceived only as paperwork [3, 4].

It begins with culture
● The culture of an organization sets the tone for
everything in the safety arena.
● In a positive safety culture, the culture itself says
that everything you do about safety is important.
● In a participative environment (culture), an
organization is saying to the employee, “I want
and need your help.” Some cultures urge
creativity and innovative solutions, while others
destroy them by not caring about their
employees.
● Some cultures tap the employees for ideas and
help, while others force employees to never use
their brains at work [3, 4]. The following list
outlines some specific elements of a culture:

Elements of Culture
● How are decisions made?
● Does an organization spend available funds on
employees and safety? Or are these ignored in favor
of other things—for example, production, quality,
new equipment, or other business opportunities?
● How are employees measured? Is safety measured
as tightly as production with defined activities? What
is measured tightly is what is important to
management.
● How are employees rewarded? Is there a greater
reward for productivity than for safety? This shows
management’s real priorities (values).
● Is teamwork mastered? Or is it “us versus them”? In
safety, is it “police versus policed”?
● What is the history? What are your traditions?
● Is your management system in place to protect
employees or to comply with regulations?

Elements of Culture
● Is your management system in place to protect
employees or to comply with regulations?
● Are supervisors required to do safety tasks daily?
● Do big “bosses” (top management) walk around the
facility and talk to employees?
● Are you allowed to use to use your brain or are you
just a puppet (gopher)?
● Has your company downsized? Is there always a
threat of downsizing?
● Is the company profitable? Too much? Too little? Is
the company satisfied with its level of profit? Or do
they just want more and more, never getting
enough?
● Can managers and supervisors talk about safety as
they can about quality and production? [3, 4]

Culture dictates results
● As you can see, a culture is defined by
an infinite number of things.
● It is more important to understand what
the culture is than to understand why
it is that way [3, 4].
● We have suggested that culture dictates
which program elements will work and
which will not.
● Culture dictates results, and what the
incident record will be. This is true no
matter whether we look at frequency or
severity [3, 4].

Douglas McGregor
● In many cases, a culture fails based
on the management style.
● Every management “rules” with a
different style.
● Douglas McGregor, who
specialized in human behavior in
organizations,
● Famous for his formulation of
Theory X (authoritarian
management) versus Theory Y.

● Such assumptions, McGregor pointed out, had a deep implication for management.
● Where Theory X offered management an easy scapegoat for failure, because of its emphasis
on the innate nature and limitations of its human resources Theory Y placed all problems
“squarely in the lap of management.”
● If employees were lazy or unwilling to show initiative or responsibility, if they were indifferent or
intransigent, the fault lay in management methods.

Theory X and Y
● In other words, McGregor was
redefining the old military adage:
“There are no bad troops, only bad
officers” [2].
● Theory Y challenged management
“to innovate, to discover new ways
of organizing and directing human
effort,

Values and Culture: Reactive,
Proactive, Predictive
● When we talk about ways to change or create a proactive safety culture,
we need to recognize and understand the full impact that values have on
an organization.

Social Mirror
● If you view these concepts from the other side
of the fence (the human side), you will find
that employees bring their own set of
personal beliefs and judgment to an
organization.
● This forms the foundation of unique personal
characteristics and is sometimes difficult to
change because people are shaped and
influenced early in life by our parents and our
social environment.
● “Most people are a function of the social
mirror, scripted by the opinion, the
perceptions, the paradigms of the people
around them”

Normal
● How about norms? Do values become norms? Is this how we operate a business?
● Norms have been described as unwritten rules, beliefs, attitudes, and/or practices that demonstrate
proper or improper action. Norms can become expressions of personal and organizational values .
● Many professionals will say that norms can be accomplished through observable behaviors of
employees.
● For example, we believe that everyone can remember when a member of management knowingly
permits an employee to operate equipment without proper guarding or without wearing personal
protective equipment (PPE.) Why?
● Probably because the manager “did not have the time” to say anything to the employee or it would have
slowed production.
● In these unspoken words, this is known as: “Production is #1 and safety is not important.”
● The norm is to take chances if the objective is to speed up production.

Safety Culture
● Although climate is difficult to define, it
is easy to see and feel.
● According to Petersen, “Probably the
best definition I’ve ever heard on culture
came from a worker I interviewed who
stated, ‘Culture is the way it is around
here.’ It’s the unwritten rules of the
ballgame that the organization is
playing.
● Culture is what everybody knows, and
therefore it does not have to be stated
or written down”

Safety Culture
● Safety climate reflects if safety is
perceived by all employees to be a
“key value” in the organization.
● The terms “climate” and “culture”
are both used here [3,
● The question is: has a safety
climate (culture) been created
that is conducive to adopting
safe work attitudes and habits [3,
4]?

Concept of Culture
● The concept of culture became a very
popular management subject in the
early 1980s, because of the
popularity of a book written by Peters
and Waterman, In Search of
Excellence.
● That book described what it was that
accounted for the economic success
of a number of companies.
● Other books followed, delving into the
concept [3, 4].

Organizational Climate/Culture
● The concept of culture had been around
long before In Search of Excellence was
published.
● Dr. Rensis Likert wrote a book called
The Human Organization, where he
described his research on “trying to”
understand the difference in “styles” of
different companies, and how these
“styles” affected the bottom line.
● Dr. Likert coined the term
“Organizational Climate.” We now call it
culture [3, 4].

Culture
● According to Petersen, Likert believed
that participative management was
the best kind, and the most likely to
produce results.
● Some of his contemporary management
thinkers criticized him for flatly
assuming that group discussion was the
only path to good decision-making and
thereby abandoning or ignoring the
search for better techniques of problem
solving or decision-making [2].

Participative Management
● Participative management is defined as a
management style in which leaders place
emphasis on employees’ involvement in the
management process.
● This is usually accomplished by providing
employees with ample opportunities to
become involved in the processes of setting
goals, making suggestions, improving
company operations, and solving problems.
● The basic premise for participative
management is to shift the burden of decision
making from the sole shoulders of managers
and supervisors onto the entirety of the
company. This provides a number benefits to
various types of businesses.

Climate Defined
● Likert not only researched climate; he also defined it as
being excellent in ten areas:
● Confidence and trust
● Interest in the subordinate’s future
● Understanding of and the desire to help overcome
problems Training and helping the subordinate to
perform better
● Teaching subordinates how to solve problems rather
than giving the answers
● Giving support by making available the required
physical resources Communicating information that the
subordinate must know to do the job as well as
information needed to identify more with the operation
● Seeking out and attempting to use ideas and opinions
Approachability
● Crediting and recognizing accomplishments

Measuring Climate
● Likert invented a way to measure climate with a
forced choice questionnaire that he administered
to employees to find out their perception of how
good the company is in the ten areas.
● He later took the perception survey results and
ran correlation studies with things like profitability,
return on investment, growth, and other bottom-
line figures, invariably coming up with extremely
high positive correlation.
● Apparently, climate determines results [3, 4].
● Likert’s research method was based on detailed
questionnaires, asking employees a series of
questions about their supervisors.
● He then drew up a profile of each
supervisor/manager in light of how they were
viewed by the employees [2].

Management Styles
● Exploitative authoritarian
● Benevolent authoritarian
● Consultative
● Participative

Exploitative Authoritarian
● Management is by fear and
coercion, where communication is
top-down, decision-making is done
at the top with no shared
communication, and management
and employees are psychologically
far apart.

Benevolent Authoritarian
● Management is by carrot rather
than stick, but employees are still
subservient; such information that
flows upward is mainly what the
manager is thought to want to hear,
and policy decisions are taken at
the top, with only minor ones
delegated to a lower level.

Consultative
● Management uses both carrot and
stick and does try to talk to
employees; communication flows
both ways, but is still somewhat
limited upward; important decisions
are still taken top down.

Participative
● Management provides economic rewards and is con-
cerned to get employees involved in groups capable
of making decisions;
● it sets challenging goals and works closely with
employees to encourage high performance.
● Communication flows easily in both directions and
sideways to peers; management and employees are
psychologically close.
● Decision-making is done through participative
processes; work groups are integrated into the formal
structure of the organization by creating a series of
overlapping groups, each linked to the rest of the
organization by a “linking pin,” preferably a team
leader or departmental manager, who will be a
member of both group and management.

Conformance Appraisal
● Before we begin our journey, let discuss one more
misunderstood concept: audits.
● How many “audits” have you performed?
● What does the word audit mean?
● Typically, it means that you have to find something
wrong. In one author’s opinion, this is the case with
most auditors.
● We need to get over this attitude and stop
looking for all the “bad” things that have
happened.
● We encourage you to look at “audit” as a
“conformance appraisal,” which means looking
at your management system to see how it
conforms to your expectations.
● This will help you to keep a positive focus on
conformance to practices and procedures of the
man-agement system and/or program
requirements. We continually need to
understand how to focus on the positive
aspects of safety.

Management Behaviors
● One thing that we often forget that is as important as,
if not more important than, employee behaviors
is management behaviors.
● If management is trying to create or improve the
safety management system, they need to make
sure that they demonstrate the same behaviors
they expect from their employees.
● Employees are watching management carefully
during any process change.
● If management’s personal behavior is not consistent
with the verbal and written messages they are
sending, then the process will not work, the safety
culture will not be trustworthy, and the management
system will fail.

Management System
● The management system and the
safety program should be evaluated
to make sure that it is effective and
appropriate to specific workplace
conditions.
● The management system must be
revised in a timely manner to identify
and help correct infractions during a
management system evaluation
● It is a living process—you must
continue to feed the system.

Management System
If you are part of top management, you have assigned specific responsibilities to your managers and supervisors.
You want to avoid
● trying to undermine their authority and interfere with their accountability,
● since that may hurt their ability to effectively carry out their assigned responsibilities.
● At the same time, you want to make sure that you demonstrate
your own commitment to help increase awareness.
How do you walk this fine line between being the doer and being the implementer?
The following are some suggestions that can help you to achieve a balance:
• Hold all managers and supervisors accountable for their activities
• Work with your employees to develop a comprehensive safety program
• Encourage employee participation to use established reporting systems
• Forge a partnership with all managers and supervisors to help encourage employee participation to speak out and
use the established system
• The success of any safety meeting depends on how you create a climate where employees feel free to speak up,
and how you handle the questions.

Employee Participation
Involving all employees in the management system is one of the most effective approaches you
can take to develop an effective safety culture.
The following are some recommended solutions that you can use to encourage employee
participation:
• Show your commitment through management support and leadership. This helps your employees to
believe that you want a safe workplace, whatever it takes.
• Communicate clearly to your employees that a safe workplace is a condition of their employment.
• Tell your employees what you expect of them. Document the requirements. Communicate to all
employees specific responsibilities in the safety program, appropriate training, and adequate resources
for performing specific activities that were assigned.
• Get as many employees involved as possible: brainstorming, inspecting, detecting, and correcting.
• Make sure that employee participation is expected as part of the job during normal working hours or
as part of their assigned normal jobs.
• Take your employees seriously. Implement their safety suggestions in a timely manner, or take time
to explain why they cannot be implemented.
• Make sure co-workers hear about it when other employee ideas are successful.

Employee Participation
What can employees do to be involved? The following are some examples of
employee participation:
• Participating on joint labor—management committees (as applicable) and other
advisory or specific purpose committees (short-term projects)
• Conducting workplace inspections
• Analyzing routine hazards in each step of a job or process (JHA), and preparing
safe work practices or controls to eliminate or reduce exposure
• Developing and revising the workplace safety rules
• Training both current and newly hired/transferred and seasoned employees
• Providing programs and presentations at safety meetings
• Conducting and participating in incident investigations
• Reporting hazards and fixing hazards under their control
• Supporting co-workers by providing feedback on risks and assisting them in
eliminating hazards
• Performing a pre-use or change analysis for new equipment or processes in order
to identify hazards up front before use

Leading and Lagging Indicators
● One of the issues we struggle with is focusing on OSHA Incident Rates
(OIR)
● In many cases, management has a tendency to focus on how well they are
doing by using numbers to measure safety program success.
● This happens with your insurance pricing as well (average you out)
● We do not have a problem with presenting these statistics to management,
but one must remember that people get hurt, not numbers.
● You must learn to focus on individuals (employees) as opposed to how the
numbers line up and continue to look at leading indicators.

Change starts from the top
● As top management, your visible commitment to safety can make a major difference in the
quality of your employees’ work and personal life.
● You can choose among a variety of formal and informal methods and styles for achieving
this impact.
● Demonstrate to everyone that you are vitally interested in employee safety.
● Do this by making yourself accessible: encourage your employees to speak up about
safety, listen carefully, and then follow through.
● Set a good example: follow the rules, make time to carry out your safety responsibilities,
and insist that all managers and supervisors do the same.
● Make sure everyone understands that you are in charge of a business where safety will not
be compromised and where hazard awareness and safe work practices are expected of
everyone, including on-site contractors and their employees.

HR’s: Bermuda Triangle
What are you as the employer eligible to provide in during an employee’s absence
(illness or injury) Here are 8 steps to follow to avoid HR Bermuda triangle (ADA,
FMLA, Workers comp):
ADA, FMLA, Workers Comp: Make sure you know:
● The purpose of each of the laws
● Importance of analyzing (and understanding) how the laws interact
● When and how the laws interact – and what to do about it

Law Criteria
ADA  15 employees for 20 weeks during current or preceding calendar year
FMLA  50 employees with a 75-mile radius for a least 20 weeks during current or
preceding calendar year
WC Most, even small employers - check State laws!
Step 1 Check Employer Coverage
Law Criteria
ADA Disabled employee OR applicant able to perform essential functions with or without
reasonable accommodation
FMLA Employee who worked at least 12 months and 1,250 hours
WC Employee injured or ill due to work-related incident
Step 2 Check Employee Eligibility

Law Length of Leave
ADA No time limit
FMLA 12 weeks or 26 weeks for Service member related illness/injury
WC No time limit
Step 3 Determine the Length of leave
Law Documentation
ADA Regarding disability that prevents or limits the performance of essential job duties
FMLA DOL Medical Certification Form
WC Pertaining to the employee’s on-the-job injury/illness
Step 4 Opting medical documentation

Step 5 Check benefits while on leave
Step 6 Determine if restricted or light duty available

Step 7 Return to work certificate available
Step 8: Reinstatement
Law Criteria
ADA Required to previous job unless an undue hardship
FMLA Same or equivalent job. NO undue hardship exception
WC Only in retaliatory discharge case

These are complicated laws.
Compliance is mandatory.
Violations can be costly.
Employers have a morale and ethical responsibility to assure
that employees receive the benefits and protections these
laws provide.

James Rhoad
616.307.0285
jrhoad@ottawakent.com

Building an Effective Safety Culture

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