Relying on Compliance as a Safety Performance Measure
Safety regulations are devised by government agencies to define minimum standards of practice to minimize health and safety risks. A key term in this definition is minimum standards, meaning organizations avoid penalties if all regulatory boxes are checked. But safety systems in industrial workplaces often rely too heavily on their regulatory compliance as the principal measure of their safety performance. The assumption is that if there is no deficiency to penalize, safety performance must be excellent.
Compliance, in this context, is a “trailing indicator”, meaning it is an indication of past performance only. It does not indicate present or future safety performance, nor does it provide insight into what potential hazards may manifest. As such, many safety professionals’ jobs are reduced to merely monitoring compliance. When a company focuses too much on using trailing indicators to measure safety performance, the system is overly reactive rather than preventative, and improvement can occur only if an unmet regulation is discovered or after a safety incident occurs.
Also, the term minimum standards mean that an organization’s safety standards can exceed what the regulations address. Although the advent of safety regulations led to a decline in incidents over the past many decades, the decline has steadied more recently. This suggests a limit to regulations’ ability to minimize incidents or a limit to the ability to comply with an ever-growing number of regulatory guidelines.
So, Who Benefits Most from Workplace Safety Regulations?
Regulations are often considered too prescriptive rather than directive, difficult to consistently meet, and even sometimes incompatible with the industry or individual company. So who do safety regulations benefit most?
From an employer’s perspective, safety regulations provide guidance for the health and safety needs that a workplace must meet to be compliant and minimally safe. Employers can review existing regulations to also understand what health and safety issues might be overlooked or cannot be realistically addressed by regulations, like worker fatigue risk. This allows employers to buttress their safety systems and avoid the problems in believing that safety regulations are infallibly comprehensive.
For instance, fatigue is a known and common contributor in workplace accidents, but a regulation cannot realistically forbid workers from being fatigued, not least because the cause of fatigue does not have to be work-related. As a result, OSHA provides much useful information about managing fatigue risk in the workplace, but there are no associated regulations for employers to follow.
From an employee’s perspective, the company’s regulatory compliance may suggest safety performance, but most employees recognize from experience that compliance alone is insufficient in preventing future risk. Regulations are merely words on a page that do not always accurately reflect their work environment or circumstances. Yet, like their employers, employees also often look at their company’s compliance as a report card for their safety performance simply for lack of better ways.
Therefore, regulatory guidelines are necessarily beneficial but they principally serve the government agencies that create them. Because regulations are general or generic by nature, as to be applicable in as many circumstances as possible, their benefits are best seen when looking at industries as a whole rather than at the level of specific employees and employers. This is because compliance with regulations and safe performance are not necessarily the same thing, and individuals must both know and follow the regulatory guidelines. The mere existence of the regulation does not automatically influence safety performance at the individual level.
Workplace Safety Regulations - Beyond Compliance
Individual employers and employees have many opportunities to improve safety at their organizations in ways that make sense for them specifically, beyond what regulatory compliance alone can do. This means, for example, introducing technology incorporating data analytics to forecast fatigue risk, like in Predictive Safety’s PRISM platform, or to identify diminished alertness in the moment and in the field, like with Predictive Safety’s AlertMeter®.
Both of these technologies go beyond relying on trailing indicators and use leading indicators to mitigate or even eliminate safety risks. Unlike a “point-of-failure” solution, which is triggered only once a risk is identified, PRISM and AlertMeter® notify of potential risks before the risk can manifest. It represents a way to measure current safety performance and future safety or productivity issues in a way that regulatory compliance alone cannot.
Your organization can stop reacting and start preventing by addressing the significant risk posed by cognitive impairment and fatigue.
